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In re Munson and Beal

169 N.H. 274, 146 A.3d 153 (2016)

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In re Munson and Beal

New Hampshire Supreme Court

169 N.H. 274, 146 A.3d 153 (2016)

Facts

In 1993 Deborah Munson (plaintiff) and Coralee Beal (defendant) began a 15-year period of cohabitation. In 2008 Munson and Beal entered a civil union. In 2011 Munson and Beal’s civil union became a marriage. In 2012 Munson filed for divorce on the ground of irreconcilable differences. In determining an equitable division of the couple’s marital property, the trial court considered the 2008 civil union as the beginning of the marriage. The court awarded Beal only 12 percent of the marital estate—an unequal distribution informed by the court’s perception of the marriage as short-term. Beal appealed, arguing that the 15-year cohabitation, which included extensive commingling of financial assets, should have been considered by the court. Beal also noted that the illegality of same-sex marriage made marriage impossible during this period of cohabitation. The New Hampshire Supreme Court granted certiorari.

Rule of Law

Issue

Holding and Reasoning (Hicks, J.)

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