Allen v. Hart

CourtSupreme Court of Delaware
DecidedApril 8, 2024
Docket402, 2023 / 73, 2024
StatusPublished

This text of Allen v. Hart (Allen v. Hart) is published on Counsel Stack Legal Research, covering Supreme Court of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Allen v. Hart, (Del. 2024).

Opinion

IN THE SUPREME COURT OF THE STATE OF DELAWARE

JORDAN ALLEN,1 § § Respondent Below, § No. 402, 2023 Appellant, § § Court Below—Family Court v. § of the State of Delaware § DELLA HART, § File No. CN22-04221 § Petition No. 22-17146 Petitioner Below, § Appellee. §

DELLA HART, § § Respondent Below, § No. 73, 2024 Appellant, § § Court Below—Family Court v. § of the State of Delaware § JORDAN ALLEN, § File No. CN22-04221 § Petition No. 22-17146 Petitioner Below, § Appellee. § § CONSOLIDATED

Submitted: March 27, 2024 Decided: April 8, 2024

Before SEITZ, Chief Justice; VALIHURA and TRAYNOR, Justices.

ORDER

After consideration of the parties’ briefs and the record below, it appears to

the Court that:

1 The Court previously assigned pseudonyms to the parties under Supreme Court Rule 7(d). (1) The appellant in Appeal No. 402, 2023, Jordan Allen (“Ex-Husband”),

filed an appeal from the Family Court’s order, dated October 12, 2023, resolving

ancillary matters (“Ancillary Matters Order”). While Appeal No. 402, 2023 was

pending, the Family Court found Ex-Husband in contempt of the Ancillary Matters

Order on December 20, 2023 (“Rule to Show Cause Order”) and later granted Ex-

Husband’s motion to stay the Ancillary Matters Order pending appeal on February

15, 2024 (“Stay Order”). The appellant in Appeal No. 73, 2024, Della Hart (“Ex-

Wife”), filed an appeal from the Stay Order and sought expedited scheduling. This

Court consolidated and expedited both appeals. Having considered the parties’

positions and the record on appeal, we conclude that the Ancillary Matters Order

should be affirmed. We do not address the Stay Order, which is now moot.

(2) The parties were married on March 10, 1991, separated on November

1, 2019, and divorced on February 10, 2023. The Family Court retained jurisdiction

over property division, alimony, court costs, and attorneys’ fees. On August 3, 2023,

the Family Court granted Ex-Wife’s motion to compel Ex-Husband’s response to

her document production requests.

(3) On September 12, 2023, the Family Court held a hearing on ancillary

matters. Ex-Husband still had not produced all of the financial documents

responsive to Ex-Wife’s discovery requests. During the hearing, the Family Court

heard testimony from both parties and one of Ex-Wife’s doctors.

2 (4) On October 12, 2023, the Family Court issued the Ancillary Matters

Order. The Family Court ordered the sale of the marital residence, warning that if

Ex-Husband failed to act in good faith in taking the necessary steps for the sale, then

Ex-Wife would become responsible for the sale. Applying 13 Del. C. § 1513, the

court held that all non-retirement assets, including the proceeds from the sale of the

marital residence, would be apportioned 60% to Ex-Wife and 40% to the Ex-

Husband with the reverse for marital debts. Applying 13 Del. C. § 1512, the court

concluded that Ex-Wife was dependent and ordered Ex-Husband to pay alimony of

$830.00 per month beginning on October 15, 2023. The Family Court also ordered

Ex-Husband to re-name Ex-Wife as the primary beneficiary of an insurance policy

obtained during the marriage. Finally, the Family Court denied Ex-Wife’s request

that Ex-Husband reimburse her for attorneys’ fees and court costs.

(5) On October 31, 2023, Ex-Husband filed an appeal of the Ancillary

Matters Order in this Court. On November 22, 2023, Ex-Wife filed a petition for a

rule to show cause alleging that Ex-Husband was in contempt of the Ancillary

Matters Order because, among other things, he had not retained a realtor or paid any

alimony. After a hearing on December 20, 2023, the Family Court issued the Rule

to Show Cause Order. The Family Court found Ex-Husband in contempt of the

Ancillary Matters Order and granted Ex-Wife exclusive authority to list and sell the

house. Ex-Husband did not appeal the Rule to Show Cause Order.

3 (6) On January 29, 2024, Ex-Wife filed another petition for a rule to show

cause and a motion for a court order authorizing the court clerk to sign the deed and

other documents related to the upcoming sale of the house. Ex-Wife alleged that

Ex-Husband refused to sign the settlement papers for the sale, which was scheduled

to close on February 16, 2024. On February 13, 2024, counsel entered an appearance

for Ex-Husband (who had been appearing pro se) and filed a motion to stay the

Ancillary Matters Order pending appeal. Ex-Wife opposed the motion. After a

hearing on February 14, 2024, the Family Court granted Ex-Husband’s motion to

stay, but ruled that any financial losses Ex-Wife suffered as a result of the failed

settlement and Ex-Husband’s failure to pay the utilities and mortgage would be

reimbursed to Ex-Wife from the Ex-Husband’s share of the eventual sale proceeds.

On February 22, 2024, Ex-Wife filed an appeal of the Stay Order in this Court.

(7) This Court reviews the Family Court’s factual and legal determinations

as well as its inferences and deductions.2 We will not disturb the Family Court’s

rulings on appeal if the court’s findings of fact are supported by the record and its

explanations, deductions, and inferences are the product of an orderly and logical

2 Wife (J.F.V.) v. Husband (O.W.V., Jr.), 402 A.2d 1202, 1204 (Del. 1979). 4 reasoning process.3 We review legal rulings de novo.4 If the Family Court correctly

applied the law, then our standard of review is abuse of discretion.5

(8) We first address Ex-Husband’s arguments in Appeal No. 402, 2023.6

Ex-Husband’s arguments may be summarized as follows: (i) the Family Court erred

in awarding Ex-Wife 60% of the proceeds from the sale of the house because Ex-

Wife did not move out of the house in November 2019 as found by the Family Court,

Ex-Wife has chosen not to work despite having multiple degrees, and Ex-Husband

made significant contributions to the house; (ii) the Family Court failed to address

the marital debts he owes; (iii) he should not be required to pay Ex-Wife $3,900 for

her car; (iv) the Family Court erred in awarding Ex-Wife alimony; (v) he cannot

maintain the life insurance policy with Ex-Wife as the primary beneficiary because

it is tied to the house that is to be sold; and (vi) Ex-Wife filed a false tax return in

2023 and placed holds on his mail that caused delays in his receipt of mail.

(9) In determining how to divide the parties’ marital property, the Family

Court considers all relevant factors, including the factors listed in Section 1513(a).

3 Id. 4 Forrester v. Forrester, 953 A.2d 175, 179 (Del. 2008) 5 CASA v. Dep’t of Servs. for Children, Youth and Their Families, 834 A.2d 63, 66 (Del. 2003). 6 Relying on Schmidt v. Schmidt, 610 A.2d 1374 (Del. 1992), Ex-Wife asks this Court to dismiss Ex-Husband’s appeal of the Ancillary Matters Order without reaching the merits because the Family Court found him in contempt of that order. This Court has dismissed appeals where an appellant is in contempt of the order appealed, but under the circumstances of this case we have chosen to address the merits of Ex-Husband’s appeal.

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Related

Wife (J. F. v. v. Husband (O. W. v. Jr.)
402 A.2d 1202 (Supreme Court of Delaware, 1979)
Schmidt v. Schmidt
610 A.2d 1374 (Supreme Court of Delaware, 1992)
Casa v. Department of Services for Children, Youth & Their Families
834 A.2d 63 (Supreme Court of Delaware, 2003)
Forrester v. Forrester
953 A.2d 175 (Supreme Court of Delaware, 2008)
Glanden v. Quirk
128 A.3d 994 (Supreme Court of Delaware, 2015)
Kirpat, Inc. v. Delaware Alcoholic Beverage Control Commission
741 A.2d 356 (Supreme Court of Delaware, 1998)

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Allen v. Hart, Counsel Stack Legal Research, https://law.counselstack.com/opinion/allen-v-hart-del-2024.