The appeals court's insistence on specific findings, rather than a punitive share, tightens the evidentiary standard for anyone seeking an enhanced award.
A Utah man spent at least $367,599 of marital money during divorce proceedings on items including an Airstream trailer, a BMW for one daughter and jewellery for his daughters, according to a report in the Times of India citing court records. The district court found that Brandon Reynolds Bonham had breached court orders by spending marital funds without his wife's consent, failed to disclose the expenditures and did not provide a full account of the money used.
The case, Bonham v. Bonham, turns on the legal treatment of dissipation: the spending down or disposal of marital assets by one spouse while a divorce is pending. Emily and Brandon Bonham married in July 1998 and separated in July 2019, after he admitted to an extramarital affair that produced a child, according to the report. The couple had four children, three of them minors when Emily filed, and a substantial marital estate that included a home and RMT Equipment, a business Brandon continued to operate during the proceedings.
Temporary orders required him to pay monthly family support and a salary through RMT, cover vehicle and health insurance, and share the cost of the children's existing extracurricular activities. The parties were also barred from disposing of marital property without the other's consent. After a four-day trial in August and September 2022, the district court found that Brandon had intentionally breached those restrictions on multiple occasions, spending thousands on toys, gifts, holidays and other purchases, and disclosing them only after Emily discovered them.
The lower court identified at least $367,599 in dissipation while stating the true total was probably higher. It held Brandon in contempt and ordered him to pay Emily 75% of the amount rather than the usual half, citing his repeated violations and his failure to disclose enough information to assess the estate. The Utah Court of Appeals has now reversed that 75% award, directing the district court to make adequate findings on what dissipation occurred and to award Emily half of the total established. It also reversed an award of equity in the Rolling Brook house, ordering the lower court to decide whether the property was marital or Brandon's separate property, and required further findings on his reasonable monthly expenses and tax rate for the alimony calculation, along with revisions to support arrears and a fresh assessment of attorney fees.
The ruling matters beyond one household. Dissipation findings are among the most contested elements of high-asset divorces, because they require courts to reconstruct spending that one party controls and the other may only discover late. The appeals court's insistence on specific findings, rather than a punitive share, tightens the evidentiary standard for anyone seeking an enhanced award. What remains unconfirmed is the final figure the district court will settle on, how the Rolling Brook house will be classified, and how the alimony and fee questions will be resolved. The Times of India notes that it has not independently verified the expenditures, the allegations or the court findings, and that the rulings remain subject to further review.
