Mr. Postema (husband) (defendant) and Ms. Postema (wife) (plaintiff) were married. The wife attended school to receive her associate’s degree in nursing. The couple agreed that the wife would pause her education so the husband could go to law school. While the husband attended law school, the wife worked full-time to support the couple. The wife also undertook the primary responsibility of maintaining the couple’s household. The couple divorced. The trial court ruled that the husband’s law degree was marital property. The trial court valued the degree at $80,000 and awarded the wife $32,000 on the grounds that that amount would make the parties’ total marital property distributions equal in light of other distributions. The husband appealed.