considers improper factors in Alaska

1995S.N.E. v. R.L.B., 699 P.2d 875, 878 (Alaska 1985); Starkweather v. Curritt, 636 P.2d 1181, 1182-83 (Alaska 1981); Deivert v. Oseira, 628 P.2d 575, 577 (Alaska 1981).

1995S.N.E. v. R.L.B., 699 P.2d 875, 878 (Alaska 1985); Starkweather v. Curritt, 636 P.2d 1181, 1182-83 (Alaska 1981); Deivert v. Oseira, 628 P.2d 575, 577 (Alaska 1981).

2012Trial courts enjoy broad discretion in making child custody determinations.4 “We will reverse a trial court’s resolution of custody issues only if this court is convinced that the record shows an abuse of discretion or if controlling factual findings are clearly erroneous.”5 Abuse of discretion in a child custody case is established if the trial court considers improper factors or improperly weighs certain factors in reaching its decision.6 Factual findings are clearly erroneous when a review of the entire record leaves this court with a “definite and firm conviction that a mistake 4 Vachon v.

2012STANDARD OF REVIEW We review a trial court’s custody order for an abuse of discretion.5 “Abuse of discretion in child custody cases occurs when a trial court considers improper factors or improperly weighs factors in its decisional process.”6 Factual findings are reviewed for clear error; we find clear error “when, after review of the entire record, ‘we are left with a definite and firm conviction’ a mistake occurred.”7 The trial court must make findings that “either give us a clear indication of the factors which the superior court 4 AS 25.24.150(c)(7). 5 Wee v. Eggener, 225 P.3d 1120, 1124 (

1995S.N.E. v. R.L.B., 699 P.2d 875, 878 (Alaska 1985); Starkweather v. Curritt, 636 P.2d 1181, 1182-83 (Alaska 1981); Deivert v. Oseira, 628 P.2d 575, 577 (Alaska 1981).

1995S.N.E. v. R.L.B., 699 P.2d 875, 878 (Alaska 1985); Starkweather v. Curritt, 636 P.2d 1181, 1182-83 (Alaska 1981); Deivert v. Oseira, 628 P.2d 575, 577 (Alaska 1981).

1995S.N.E. v. R.L.B., 699 P.2d 875, 878 (Alaska 1985); Starkweather v. Curritt, 636 P.2d 1181, 1182-83 (Alaska 1981); Deivert v. Oseira, 628 P.2d 575, 577 (Alaska 1981).

1995S.N.E. v. R.L.B., 699 P.2d 875, 878 (Alaska 1985); Starkweather v. Curritt, 636 P.2d 1181, 1182-83 (Alaska 1981); Deivert v. Oseira, 628 P.2d 575, 577 (Alaska 1981).

2025Third, it must decide how an allocation can be made most equitably.”2 “An abuse of discretion occurs if the court considers improper factors, fails to consider relevant statutory factors, or assigns disproportionate weight to some factors while ignoring others.”3 We will not reverse the trial court’s allocation of property unless the division was clearly unjust.4 “We review for abuse of discretion a superior court’s decision whether to give a credit to a spouse for payments made to maintain marital property, such as the family home.”5 “We have required that trial courts consider payments to ma

2025Third, it must decide how an allocation can be made most equitably.”2 “An abuse of discretion occurs if the court considers improper factors, fails to consider relevant statutory factors, or assigns disproportionate weight to some factors while ignoring others.”3 We will not reverse the trial court’s allocation of property unless the division was clearly unjust.4 “We review for abuse of discretion a superior court’s decision whether to give a credit to a spouse for payments made to maintain marital property, such as the family home.”5 “We have required that trial courts consider payments to ma

2025Third, it must decide how an allocation can be made most equitably.”2 “An abuse of discretion occurs if the court considers improper factors, fails to consider relevant statutory factors, or assigns disproportionate weight to some factors while ignoring others.”3 We will not reverse the trial court’s allocation of property unless the division was clearly unjust.4 “We review for abuse of discretion a superior court’s decision whether to give a credit to a spouse for payments made to maintain marital property, such as the family home.”5 “We have required that trial courts consider payments to ma

2021See Stanhope v. Stanhope, 306 P.3d 1282, 1288 (Alaska 2013) (reviewing for clear error finding that one spouse wasted marital assets); Elliot v. James, 977 P.2d 727, 733 (Alaska 1999) (holding “court’s finding that neither party unreasonably depleted marital assets [was] not clearly erroneous”). 5 Wiegers, 420 P.3d at 1182 . 6 Wagner v. Wagner, 386 P.3d 1249, 1251 (Alaska 2017); see also Engstrom, 350 P.3d at 769 (“An abuse of discretion occurs if the court considers improper factors, fails to consider relevant statutory factors, or assigns disproportionate weight to some factors while ignorin

2020Servs., Office of Children’s Servs., 174 P.3d 217, 220 (Alaska 2007)). 22 Sheffield v. Sheffield, 265 P.3d 332, 335 (Alaska 2011) (quoting (continued...) -7- 1760 the equitable allocation of property, for an abuse of discretion.”23 “An abuse of discretion occurs if the court considers improper factors, fails to consider relevant statutory factors, or assigns disproportionate weight to some factors while ignoring others.”24 IV.

2015Servs., Office of Children’s Servs., 174 P.3d 217, 220 (continued...) -4- 7006 review for clear error.”6 “We review the trial court’s third step, the equitable allocation of property, for an abuse of discretion.”7 “An abuse of discretion occurs if the court considers improper factors, fails to consider relevant statutory factors, or assigns disproportionate weight to some factors while ignoring others.”8 A superior court “has broad discretion to provide for the equitable division of property between the parties in a divorce,” and we “will reverse only if the division [was] clearly unjust.”9 We

2013In making a custody determination, the superior court must consider the factors listed in AS 25.24.150(c).9 The court’s findings must “give a clear indication 4 (...continued) (Alaska 2005). 5 Wee v. Eggener, 225 P.3d 1120, 1124 (Alaska 2010) (citing Jaymot v. Skillings-Donat, 216 P.3d 534, 538-39 (Alaska 2009)). 6 Id. (quoting Dingeman v. Dingeman, 865 P.2d 94, 96 (Alaska 1993)). 7 Hunter v. Conwell, 276 P.3d 413, 418 (Alaska 2012) (quoting Millette v. Millette, 177 P.3d 258, 261 (Alaska 2008)). 8 Pam R. v. State, Dep’t of Health & Soc.

2012STANDARD OF REVIEW We review a trial court’s custody order for an abuse of discretion.5 “Abuse of discretion in child custody cases occurs when a trial court considers improper factors or improperly weighs factors in its decisional process.”6 Factual findings are reviewed for clear error; we find clear error “when, after review of the entire record, ‘we are left with a definite and firm conviction’ a mistake occurred.”7 The trial court must make findings that “either give us a clear indication of the factors which the superior court 4 AS 25.24.150(c)(7). 5 Wee v. Eggener, 225 P.3d 1120, 1124 (

2013In making a custody determination, the superior court must consider the factors listed in AS 25.24.150(c).9 The court’s findings must “give a clear indication 4 (...continued) (Alaska 2005). 5 Wee v. Eggener, 225 P.3d 1120, 1124 (Alaska 2010) (citing Jaymot v. Skillings-Donat, 216 P.3d 534, 538-39 (Alaska 2009)). 6 Id. (quoting Dingeman v. Dingeman, 865 P.2d 94, 96 (Alaska 1993)). 7 Hunter v. Conwell, 276 P.3d 413, 418 (Alaska 2012) (quoting Millette v. Millette, 177 P.3d 258, 261 (Alaska 2008)). 8 Pam R. v. State, Dep’t of Health & Soc.

2012Trial courts enjoy broad discretion in making child custody determinations.4 “We will reverse a trial court’s resolution of custody issues only if this court is convinced that the record shows an abuse of discretion or if controlling factual findings are clearly erroneous.”5 Abuse of discretion in a child custody case is established if the trial court considers improper factors or improperly weighs certain factors in reaching its decision.6 Factual findings are clearly erroneous when a review of the entire record leaves this court with a “definite and firm conviction that a mistake 4 Vachon v.

2013In making a custody determination, the superior court must consider the factors listed in AS 25.24.150(c).9 The court’s findings must “give a clear indication 4 (...continued) (Alaska 2005). 5 Wee v. Eggener, 225 P.3d 1120, 1124 (Alaska 2010) (citing Jaymot v. Skillings-Donat, 216 P.3d 534, 538-39 (Alaska 2009)). 6 Id. (quoting Dingeman v. Dingeman, 865 P.2d 94, 96 (Alaska 1993)). 7 Hunter v. Conwell, 276 P.3d 413, 418 (Alaska 2012) (quoting Millette v. Millette, 177 P.3d 258, 261 (Alaska 2008)). 8 Pam R. v. State, Dep’t of Health & Soc.

2012STANDARD OF REVIEW We review a trial court’s custody order for an abuse of discretion.5 “Abuse of discretion in child custody cases occurs when a trial court considers improper factors or improperly weighs factors in its decisional process.”6 Factual findings are reviewed for clear error; we find clear error “when, after review of the entire record, ‘we are left with a definite and firm conviction’ a mistake occurred.”7 The trial court must make findings that “either give us a clear indication of the factors which the superior court 4 AS 25.24.150(c)(7). 5 Wee v. Eggener, 225 P.3d 1120, 1124 (

2012Trial courts enjoy broad discretion in making child custody determinations.4 “We will reverse a trial court’s resolution of custody issues only if this court is convinced that the record shows an abuse of discretion or if controlling factual findings are clearly erroneous.”5 Abuse of discretion in a child custody case is established if the trial court considers improper factors or improperly weighs certain factors in reaching its decision.6 Factual findings are clearly erroneous when a review of the entire record leaves this court with a “definite and firm conviction that a mistake 4 Vachon v.

2012Trial courts enjoy broad discretion in making child custody determinations.4 “We will reverse a trial court’s resolution of custody issues only if this court is convinced that the record shows an abuse of discretion or if controlling factual findings are clearly erroneous.”5 Abuse of discretion in a child custody case is established if the trial court considers improper factors or improperly weighs certain factors in reaching its decision.6 Factual findings are clearly erroneous when a review of the entire record leaves this court with a “definite and firm conviction that a mistake 4 Vachon v.

2025Third, it must decide how an allocation can be made most equitably.”2 “An abuse of discretion occurs if the court considers improper factors, fails to consider relevant statutory factors, or assigns disproportionate weight to some factors while ignoring others.”3 We will not reverse the trial court’s allocation of property unless the division was clearly unjust.4 “We review for abuse of discretion a superior court’s decision whether to give a credit to a spouse for payments made to maintain marital property, such as the family home.”5 “We have required that trial courts consider payments to ma

2025Third, it must decide how an allocation can be made most equitably.”2 “An abuse of discretion occurs if the court considers improper factors, fails to consider relevant statutory factors, or assigns disproportionate weight to some factors while ignoring others.”3 We will not reverse the trial court’s allocation of property unless the division was clearly unjust.4 “We review for abuse of discretion a superior court’s decision whether to give a credit to a spouse for payments made to maintain marital property, such as the family home.”5 “We have required that trial courts consider payments to ma

2025Third, it must decide how an allocation can be made most equitably.”2 “An abuse of discretion occurs if the court considers improper factors, fails to consider relevant statutory factors, or assigns disproportionate weight to some factors while ignoring others.”3 We will not reverse the trial court’s allocation of property unless the division was clearly unjust.4 “We review for abuse of discretion a superior court’s decision whether to give a credit to a spouse for payments made to maintain marital property, such as the family home.”5 “We have required that trial courts consider payments to ma

2025Third, it must decide how an allocation can be made most equitably.”2 “An abuse of discretion occurs if the court considers improper factors, fails to consider relevant statutory factors, or assigns disproportionate weight to some factors while ignoring others.”3 We will not reverse the trial court’s allocation of property unless the division was clearly unjust.4 “We review for abuse of discretion a superior court’s decision whether to give a credit to a spouse for payments made to maintain marital property, such as the family home.”5 “We have required that trial courts consider payments to ma

2022STANDARD OF REVIEW The equitable division of assets in a divorce has three steps.2 “First, the trial court must determine what property is available for distribution, characterizing the property as either separate or marital . . . .”3 We review this determination for abuse of discretion, which “occurs if the court considers improper factors, fails to consider relevant statutory factors, or assigns disproportionate weight to some factors while 2 Limeres v. Limeres, 320 P.3d 291, 296 (Alaska 2014). 3 Hansen v. Hansen, 119 P.3d 1005, 1009 (Alaska 2005). -5­ 1912 ignoring others.”4 “We apply our i

2021See Stanhope v. Stanhope, 306 P.3d 1282, 1288 (Alaska 2013) (reviewing for clear error finding that one spouse wasted marital assets); Elliot v. James, 977 P.2d 727, 733 (Alaska 1999) (holding “court’s finding that neither party unreasonably depleted marital assets [was] not clearly erroneous”). 5 Wiegers, 420 P.3d at 1182 . 6 Wagner v. Wagner, 386 P.3d 1249, 1251 (Alaska 2017); see also Engstrom, 350 P.3d at 769 (“An abuse of discretion occurs if the court considers improper factors, fails to consider relevant statutory factors, or assigns disproportionate weight to some factors while ignorin

2021See Stanhope v. Stanhope, 306 P.3d 1282, 1288 (Alaska 2013) (reviewing for clear error finding that one spouse wasted marital assets); Elliot v. James, 977 P.2d 727, 733 (Alaska 1999) (holding “court’s finding that neither party unreasonably depleted marital assets [was] not clearly erroneous”). 5 Wiegers, 420 P.3d at 1182 . 6 Wagner v. Wagner, 386 P.3d 1249, 1251 (Alaska 2017); see also Engstrom, 350 P.3d at 769 (“An abuse of discretion occurs if the court considers improper factors, fails to consider relevant statutory factors, or assigns disproportionate weight to some factors while ignorin

2021See Stanhope v. Stanhope, 306 P.3d 1282, 1288 (Alaska 2013) (reviewing for clear error finding that one spouse wasted marital assets); Elliot v. James, 977 P.2d 727, 733 (Alaska 1999) (holding “court’s finding that neither party unreasonably depleted marital assets [was] not clearly erroneous”). 5 Wiegers, 420 P.3d at 1182 . 6 Wagner v. Wagner, 386 P.3d 1249, 1251 (Alaska 2017); see also Engstrom, 350 P.3d at 769 (“An abuse of discretion occurs if the court considers improper factors, fails to consider relevant statutory factors, or assigns disproportionate weight to some factors while ignorin

2021See Stanhope v. Stanhope, 306 P.3d 1282, 1288 (Alaska 2013) (reviewing for clear error finding that one spouse wasted marital assets); Elliot v. James, 977 P.2d 727, 733 (Alaska 1999) (holding “court’s finding that neither party unreasonably depleted marital assets [was] not clearly erroneous”). 5 Wiegers, 420 P.3d at 1182 . 6 Wagner v. Wagner, 386 P.3d 1249, 1251 (Alaska 2017); see also Engstrom, 350 P.3d at 769 (“An abuse of discretion occurs if the court considers improper factors, fails to consider relevant statutory factors, or assigns disproportionate weight to some factors while ignorin

2020Servs., Office of Children’s Servs., 174 P.3d 217, 220 (Alaska 2007)). 22 Sheffield v. Sheffield, 265 P.3d 332, 335 (Alaska 2011) (quoting (continued...) -7- 1760 the equitable allocation of property, for an abuse of discretion.”23 “An abuse of discretion occurs if the court considers improper factors, fails to consider relevant statutory factors, or assigns disproportionate weight to some factors while ignoring others.”24 IV.

2013STANDARD OF REVIEW “Because the superior court has broad discretion in deciding child custody issues,” we will not reverse a superior court’s custody decision unless the superior court “abused its discretion or the controlling factual findings are clearly erroneous.”6 “Abuse of discretion is established if the trial court considers improper factors in making its custody determination, failed to consider statutorily mandated factors, or assigned 5 The superior court also expressly noted that “the court makes no finding as to [Lana’s] continued status.” 6 Helen S.K. v. Samuel M.K., 288 P.3d 463,

2013We hold pro se litigants to a less stringent standard than lawyers, and we read their pleadings and briefing generously.4 We review a trial court’s custody order for abuse of discretion, 4 Bauer v. State, Dep’t of Corr., 193 P.3d 1180, 1184 (Alaska 2008) (citing Breck v. Ulmer, 745 P.2d 66, 75 (Alaska 1987)); Hymes v. Deramus, 119 P.3d 963, 965 (continued...) -5- 1450 which we will find “when a trial court considers improper factors or improperly weighs factors in its decisional process.”5 We review factual findings for clear error, which we will find “when, after review of the entire record,

2013STANDARD OF REVIEW “Because the superior court has broad discretion in deciding child custody issues,” we will not reverse a superior court’s custody decision unless the superior court “abused its discretion or the controlling factual findings are clearly erroneous.”6 “Abuse of discretion is established if the trial court considers improper factors in making its custody determination, failed to consider statutorily mandated factors, or assigned 5 The superior court also expressly noted that “the court makes no finding as to [Lana’s] continued status.” 6 Helen S.K. v. Samuel M.K., 288 P.3d 463,

2013We hold pro se litigants to a less stringent standard than lawyers, and we read their pleadings and briefing generously.4 We review a trial court’s custody order for abuse of discretion, 4 Bauer v. State, Dep’t of Corr., 193 P.3d 1180, 1184 (Alaska 2008) (citing Breck v. Ulmer, 745 P.2d 66, 75 (Alaska 1987)); Hymes v. Deramus, 119 P.3d 963, 965 (continued...) -5- 1450 which we will find “when a trial court considers improper factors or improperly weighs factors in its decisional process.”5 We review factual findings for clear error, which we will find “when, after review of the entire record,

2013In making a custody determination, the superior court must consider the factors listed in AS 25.24.150(c).9 The court’s findings must “give a clear indication 4 (...continued) (Alaska 2005). 5 Wee v. Eggener, 225 P.3d 1120, 1124 (Alaska 2010) (citing Jaymot v. Skillings-Donat, 216 P.3d 534, 538-39 (Alaska 2009)). 6 Id. (quoting Dingeman v. Dingeman, 865 P.2d 94, 96 (Alaska 1993)). 7 Hunter v. Conwell, 276 P.3d 413, 418 (Alaska 2012) (quoting Millette v. Millette, 177 P.3d 258, 261 (Alaska 2008)). 8 Pam R. v. State, Dep’t of Health & Soc.

2013We hold pro se litigants to a less stringent standard than lawyers, and we read their pleadings and briefing generously.4 We review a trial court’s custody order for abuse of discretion, 4 Bauer v. State, Dep’t of Corr., 193 P.3d 1180, 1184 (Alaska 2008) (citing Breck v. Ulmer, 745 P.2d 66, 75 (Alaska 1987)); Hymes v. Deramus, 119 P.3d 963, 965 (continued...) -5- 1450 which we will find “when a trial court considers improper factors or improperly weighs factors in its decisional process.”5 We review factual findings for clear error, which we will find “when, after review of the entire record,

2012Franklin, Inc., 265 P.3d 320, 330 (Alaska 2011) (citing Jurgens v. City of North Pole, 153 P.3d 321, 326 (Alaska 2007)) (appellant abandons issues that are inadequately briefed). 3 Williams v. Barbee, 243 P.3d 995, 1000 (Alaska 2010). 4 Evans v. McTaggart, 88 P.3d 1078, 1084-85 (Alaska 2004) . 5 Id. at 1085 . -5- 1435 erroneous.’ ”6 An abuse of discretion “occurs when ‘the trial court considers improper factors, fails to consider statutorily mandated factors, or gives too much weight to some factors.’ ”7 Findings of fact will not be set aside unless clearly erroneous.

2012Franklin, Inc., 265 P.3d 320, 330 (Alaska 2011) (citing Jurgens v. City of North Pole, 153 P.3d 321, 326 (Alaska 2007)) (appellant abandons issues that are inadequately briefed). 3 Williams v. Barbee, 243 P.3d 995, 1000 (Alaska 2010). 4 Evans v. McTaggart, 88 P.3d 1078, 1084-85 (Alaska 2004) . 5 Id. at 1085 . -5- 1435 erroneous.’ ”6 An abuse of discretion “occurs when ‘the trial court considers improper factors, fails to consider statutorily mandated factors, or gives too much weight to some factors.’ ”7 Findings of fact will not be set aside unless clearly erroneous.

2012Trial courts enjoy broad discretion in making child custody determinations.4 “We will reverse a trial court’s resolution of custody issues only if this court is convinced that the record shows an abuse of discretion or if controlling factual findings are clearly erroneous.”5 Abuse of discretion in a child custody case is established if the trial court considers improper factors or improperly weighs certain factors in reaching its decision.6 Factual findings are clearly erroneous when a review of the entire record leaves this court with a “definite and firm conviction that a mistake 4 Vachon v.

2012Franklin, Inc., 265 P.3d 320, 330 (Alaska 2011) (citing Jurgens v. City of North Pole, 153 P.3d 321, 326 (Alaska 2007)) (appellant abandons issues that are inadequately briefed). 3 Williams v. Barbee, 243 P.3d 995, 1000 (Alaska 2010). 4 Evans v. McTaggart, 88 P.3d 1078, 1084-85 (Alaska 2004) . 5 Id. at 1085 . -5- 1435 erroneous.’ ”6 An abuse of discretion “occurs when ‘the trial court considers improper factors, fails to consider statutorily mandated factors, or gives too much weight to some factors.’ ”7 Findings of fact will not be set aside unless clearly erroneous.