Brown v. Brown, 2020 UT App 146 (Oct. 29, 2020)

The court of appeals affirmed the district court’s decision requiring the husband to reimburse the wife for her expenses incurred during a 22-month divorce proceeding in an amount of that exceeding what the wife earned and what the husband advanced her during the proceedings. The court held that both spouses “have ‘access to the marital estate,’… and both are entitled to rely on it to cover their ‘reasonable and ordinary living expenses’ pending entry of the divorce decree.”