Kristen Smith, Appellant-Petitioner v. Eric Smith, Appellee-Respondent (2026)

MEMORANDUM DECISION

Case Summary

[1] Kristen Smith (Wife) appeals the trial court's division of marital property following the dissolution of her marriage to Eric Smith (Husband). Specifically, she challenges the trial court's valuation of Husband's student loan balance. Finding no error in the court's valuation of the loan and thus no error in the division of the property, we affirm.

Facts and Procedural History

[2] Wife and Husband were married in 2016 and share two children, born in 2017 and 2020. In April 2024, Wife filed a petition for dissolution of marriage. A final hearing was held in September 2025. At the hearing, the parties submitted evidence relating to the marital estate, including liabilities. During Husband's testimony, he introduced a document purportedly from his student loan provider, MOHELA. The following exchange occurred:

[Husband's Attorney]: Can you tell the Court what this is, please?

[Husband]: Looks like a MOHELA student loan.

[Husband's Attorney]: And whose loan is this?

[Husband]: This is my student loan.

***

[Husband's Attorney]: ․ And the balance of that is what?

[Husband]: $20,000 - $20,549.

Tr. Vol. II pp. 161-62. Husband then moved to admit the exhibit, and Wife objected, arguing she “did not receive [the document] in discovery.” Id. at 162. The trial court did not admit the exhibit. Husband's testimony continued, and he was asked if “[$]20,549.04 is the current balance of [his] MOHELA student loan” and he answered, “Yes, ma'am.” Id. at 164.

[3] Following the hearing, the trial court dissolved the marriage and issued an order dividing the marital estate. The court valued Husband's student loan balance at $20,549.04 and assigned that debt solely to Husband. Ultimately, the court divided the marital estate forty-five percent to Husband and fifty-five percent to Wife, requiring Husband to pay Wife an equalization payment of $2,968.26. Wife now appeals.

Discussion and Decision

[4] Wife argues the trial court erred in its valuation of Husband's student loan.¹ In a dissolution action, the trial court first must determine what property to include in the marital pot and then must divide that property under the presumption that an equal division is just and reasonable. Smith v. Smith, 194 N.E.3d 63, 72 (Ind. Ct. App. 2022). “All assets and liabilities of both parties must be included in the marital pot.” Meyer v. East, 205 N.E.3d 1066, 1072 (Ind. Ct. App. 2023). “The party challenging the trial court's property division bears the burden of proof.” Smith, 194 N.E.3d at 72. We presume the dissolution court correctly followed the law and made all proper considerations when dividing the marital property and will reverse a property distribution only if there is no rational basis for the award. Id.

[5] Further, the trial court has broad discretion in ascertaining the value of property in a dissolution action. Campbell v. Campbell, 118 N.E.3d 817, 821 (Ind. Ct. App. 2019), reh'g denied, trans. denied. Its valuation will be disturbed only where the decision is clearly against the logic and effect of the facts and circumstances before the trial court. Id. “If the trial court's chosen valuation is within the range of values supported by the evidence, we will affirm.” Id. We will not reweigh evidence, and we consider the evidence in a light most favorable to the judgment. Meyer, 205 N.E.3d at 1073.

[6] The trial court valued the loan at $20,549.04. Wife argues there is no evidence to support this amount, emphasizing that Husband's student loan statement was not admitted at the hearing. But the statement was not the only evidence as to Husband's student loan balance. Husband also testified that the balance on his student loan was $20,549 and later agreed it was $20,549.04. See Tr. Vol. II pp. 162, 164.

[7] Wife contends this evidence does not support the valuation, arguing a “verbal recitation of a number, by itself, does not prove a specific value” and citing Bass v. Bass, 779 N.E.2d 582, 589 (Ind. Ct. App. 2002), trans. denied. Appellant's Br. p. 12. In Bass, the trial court found that $8,874 should be deducted from the marital home's value based on the wife's testimony that she had repairs done to the home and “guessed” those repairs cost “something like $8,000.” Bass, 779 N.E.2d at 589. We reversed, finding this testimony insufficient to support the court's valuation. But unlike in Bass, here Husband confirmed during his testimony that his loan balance was $20,549.04. See Tr. Vol. II p. 164. This testimony alone supports the trial court's valuation. Alexander v. Alexander, 927 N.E.2d 926, 935 (Ind. Ct. App. 2010) (“A valuation submitted by one of the parties is competent evidence of the value of property in a dissolution action and may alone support the trial court's determination in that regard.”).

[8] Wife further argues we should not credit this testimony because it “appears” Husband recited this information from the excluded exhibit. Appellant's Reply Br. p. 6. But she did not object to Husband's testimony during the hearing. And even if she had, we see no error, as a witness may testify to matters within their personal knowledge.² Ind. Evid. Rule 602. Based on Husband's testimony, the trial court's valuation of the loan was within the range of values supported by the evidence. Wife has failed to show the trial court abused its discretion in its valuation of Husband's student loan.

[9] Affirmed.

FOOTNOTES

1.   Husband argues any error in the valuation of his student loan balance would be harmless as to Wife because the trial court assigned the entire loan amount to Husband when dividing the marital property. But even if a debt is assigned solely to one party, its value and inclusion in the marital pot affect the overall value of the marital estate. See Birkhimer v. Birkhimer, 981 N.E.2d 111, 121 (Ind. Ct. App. 2012) (remanding for the trial court to properly value one spouse's debt and noting its value may require reconsideration of the entire division of property). Thus, any error in valuing the loan would not be harmless, and we address Wife's argument on the merits.

2.   To the extent Wife is arguing Husband's knowledge of the loan amount came solely from the excluded exhibit, we note she points to “no authority providing that a witness may not testify regarding a document not admitted into evidence.” Benefield v. State, 904 N.E.2d 239, 244 (Ind. Ct. App. 2009).

Scheele, Judge.

May, J., and Pyle, J., concur.