Horton v. Horton

785 S.E.2d 891, 299 Ga. 46, 2016 WL 2619621, 2016 Ga. LEXIS 357
CourtSupreme Court of Georgia
DecidedMay 9, 2016
DocketS16F0167
StatusPublished
Cited by26 cases

This text of 785 S.E.2d 891 (Horton v. Horton) is published on Counsel Stack Legal Research, covering Supreme Court of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Horton v. Horton, 785 S.E.2d 891, 299 Ga. 46, 2016 WL 2619621, 2016 Ga. LEXIS 357 (Ga. 2016).

Opinions

HINES, Presiding Justice.

Pursuant to this Court’s Rule 34 (4), Karen Horton (“Wife”) was granted a discretionary appeal from the final judgment and decree of divorce, as amended,1 (“Decree”) ending her marriage to Christopher L. Horton (“Husband”). The appeal was granted in order to consider whether the superior court erred in determining as a matter of law that the house titled in Husband’s name (“House”) was his separate property, and whether it erred in awarding Husband attorney fees under OCGA § 9-15-14.2 For the reasons that follow, we affirm.

[47]*47The parties were married on October 3, 2011, and separated approximately 19 months later, on May 8, 2013. There were no children of the marriage. The parties met through the use of a dating website for older adults; at the time of their marriage, Wife was in her mid-fifties, Husband was in his mid-sixties, and each had been married before. On May 31, 2013, Wife filed for divorce, alleging cruel treatment and that the marriage was irretrievably broken; she sought, inter alia, an equitable division of assets and liabilities and attorney fees and expenses of litigation. On June 20, 2013, Husband filed an answer and counterclaim for divorce; he denied Wife’s allegation of cruel treatment, agreed that the marriage was irretrievably broken, and sought an equitable division of assets and debts incurred during the marriage as well as attorney fees and expenses.

On August 18, 2014, the parties appeared for trial and stipulated: the marriage was irretrievably broken; Wife owned her home in Savannah prior to the marriage; Husband owned the House prior to the marriage; the mortgage balance on the House was $152,062.81; Wife would retain the benefits from her retirement plan, which she accumulated prior to the marriage; Husband would retain a $985 monthly annuity, which he began receiving prior to the marriage; each party would retain the vehicle and other personal property in his or her possession and be responsible for his or her own health insurance; and there was no marital debt.

After jury selection and opening statements, Wife presented her case. Wife testified that she spent more than $15,000 to remodel the House in the months leading up to the separation to prepare the property for sale. There was also testimony that on February 6, 2013, Husband deeded the House to her in contemplation of filing a [48]*48bankruptcy petition due to a large out-of- state judgment against him, and that on March 28, 2013, she deeded the House back to him after he learned that the first transfer would not place the House beyond the reach of a bankruptcy trustee. On the third day of trial, Wife rested her case, and Husband moved for a directed verdict on the issue of equitable division, noting that the parties had stipulated to the division of all personal property acquired during the marriage and arguing that Wife failed to produce sufficient evidence to find that the House or any part of it was marital property subject to equitable division. Among other things, Wife responded that the jury could find that all or part of the House was marital property because Husband deeded it to her and because of the mortgage payments she made during the marriage and the more than $15,000 in separate property that she spent on remodeling. The superior court granted Husband’s motion and dismissed the jury On September 17, 2014, the superior court entered the final judgment and decree of divorce, andón June 3,2015, entered the present Decree, additionally addressing the remaining issue of attorney fees. The superior court denied both parties’ requests for attorney fees under OCGA § 19-6-23 and Wife’s request for attorney fees under OCGA § 9-15-14, but granted Husband’s request for attorney fees under OCGA § 9-15-14, awarding him $14,876.25.

1. Wife contends that the superior court erred in determining as a matter of law that the House constituted Husband’s separate property, and therefore, improperly directed a verdict where there was evidence for the jury to determine whether an equitable division of the property was appropriate. She argues that the evidence showed [49]*49that she invested money in the House by paying for renovations, and that she contributed this money in contemplation of a sale based on Husband’s promise that they would be moving into another home; thus, there was evidence to authorize a jury to find that she was entitled to an equitable return on her investment in the House. But, the contention is unavailing.

As noted, there was no dispute that the House was Husband’s separate property at the time of the parties’ marriage. Thus, an initial question would be the effect, if any, of the brief inter-spousal transfer of the House on its original status as separate property.4 In McArthur v. McArthur, 256 Ga. 762 (353 SE2d 486) (1987), this Court determined that the marital home which the former husband and former wife acquired during the marriage, but which the husband deeded to the wife as a gift, remained “marital property” subject to equitable division and was not “separate property.” Thus, the argument is made that an inter-spousal transfer of a spouse’s separate property does not lose its status, i.e., separate or marital property, merely as a result of the inter-spousal transfer itself. However, the related question of the character or nature of the transfer must be considered, that is, whether the transfer was a gift.

[I] n circumstances involving conveyances of real property or the payment of certain funds between spouses, there has been the presumption in Georgia law that such a conveyance or payment is a gift and has the status of marital property.

Mallard v. Mallard, 297 Ga. 274, 277-278 (773 SE2d 274) (2015). In this case, the evidence was that the brief transfer to Wife was anything but a gift to her or to the marital estate, and whatever the effect of the conveyance of the House to Wife, its conveyance back to Husband in the same way confirmed its status as his separate property But, that is not the end of the inquiry

[I]f the non-marital property appreciates in value during the marriage and such appreciation results from the efforts of either or both spouses, the appreciation becomes a marital asset subject to equitable division.

[50]*50Id. at 277, citing Armour v. Holcombe, 288 Ga. 50, 51-52 (1) (701 SE2d 169) (2010). A method of equitable division is the “source-of-funds” rule, which,

entitles a spouse contributing non-marital property to an interest in the property in the ratio of the non-marital investment to the total non-marital and marital investment in the property; the remaining property becomes marital property and its value subject to equitable division.

Mallard v. Mallard, supra at 277. But, in order to utilize and benefit from this rule, there must be evidence of the appreciation of the property in relation to its fair market value during the parties’ subsequent marriage. Id.

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Cite This Page — Counsel Stack

Bluebook (online)
785 S.E.2d 891, 299 Ga. 46, 2016 WL 2619621, 2016 Ga. LEXIS 357, Counsel Stack Legal Research, https://law.counselstack.com/opinion/horton-v-horton-ga-2016.