In re Marriage of Patton
Annotate this CaseGail Patton filed for dissolution of her marriage to Bill Patton. After a bench trial, the Standing Master appointed to oversee the case entered her findings of fact, conclusions of law, and final decree of dissolution. Gail filed a motion for additional evidence pursuant to Mont. R. Civ. P. 59. Gail was subsequently diagnosed with breast cancer and filed a motion to amend the findings of reopen the case to consider evidence of her diagnosis in its division of the marital estate and maintenance (Motion to Amend). The district court declined to rule on Gail’s post-trial motions, concluding that it was not appropriate to take additional evidence about events occurring since the filing of the Standing Master's Report. The district court then adopted the Report with only minor adjustments. The Supreme Court reversed, holding that the district court erred (1) by failing to rule on Gail’s motion or otherwise to recommit the matter to the Standing Master with instructions to rule on these motions; and (2) by adopting the Report to the extent the Standing Master’s conclusions of law failed properly to consider Gail’s contributions to the marriage as a homemaker and her qualification for maintenance payments.
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