Cheney v. Cheney (Appellate Division, Third Department)

Plaintiff-wife contests that the Supreme Court should have granted her a determination of certain certifications that defendant acquired during the marriage as enhanced earnings assets. The husband did not obtain any Associate’s or Bachelor’s degrees. However, he did undergo training on specialized software that resulted in a teaching license but due to his lack of traditional academic degrees, his license use is extremely limited. Appellate Court agreed with Supreme Court that the information was insufficient to permit a determination as a matter of law whether defendant’s certifications and teaching license constitute enhanced earnings.