Katherine Dawn Brown, V. Geoffrey Bryan Thomas

CourtCourt of Appeals of Washington
DecidedJune 23, 2025
Docket86760-1
StatusUnpublished

This text of Katherine Dawn Brown, V. Geoffrey Bryan Thomas (Katherine Dawn Brown, V. Geoffrey Bryan Thomas) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Katherine Dawn Brown, V. Geoffrey Bryan Thomas, (Wash. Ct. App. 2025).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

In the Matter of the Marriage of: No. 86760-1 KATHERINE DAWN THOMAS, DIVISION ONE Respondent, UNPUBLISHED OPINION and

GEOFFREY BRYAN THOMAS,

Appellant.

COBURN, J. — Geoffrey Thomas, representing himself on appeal,

challenges the order of the superior court enforcing certain terms of a previously

entered and unchallenged final divorce decree. Thomas asserts that the superior

court’s determination of the value and division of certain disputed household

fixtures and large appliances modified the property division set forth in the

decree. We disagree. Thomas also asserts that the court had no basis to award

Katherine Brown 1 attorney fees and that the amount awarded was not

reasonable. Although the superior court did not err in determining that Thomas

was intransigent and awarding attorney fees, the superior court, based on the

record before us, did not address Thomas’s objections to the reasonableness of

1 For clarity, we refer to the Respondent as Brown, her last name at the time of this decision’s publication. No. 86760-1/2

the attorney fee award and failed to enter any findings supporting the fee award

other than a general conclusory finding that the fees are reasonable. Accordingly,

we affirm in part, reverse in part and remand for the trial court to adequately

address Thomas’ objections to the reasonableness of Brown’s requested

attorney fees and costs. 2

FACTS

The matter before us involves the enforcement of a dissolution decree

entered following a bench trial in 2023. That decree was not appealed.

Following a bench trial, the court awarded Brown sole ownership of her

pre-marital property in Woodinville as her separate property, which included a

residence thereon, less a real property award of $85,904 identified as “sweat

equity” comprised of Thomas’s “separate pre-marital contribution to the

Woodinville home.” The decree also awarded to Brown personal property

described as “all possessions currently in her possession” and awarded to

Thomas personal property described as “all possessions currently in his

possession.” 3 And in its final paragraph, the decree ordered Thomas to vacate

the Woodinville property within 60 days. 4

2 Thomas raises other challenges on appeal. None merit appellate relief as discussed below. 3 The decree also awarded each personal property as listed in “Exhibit A&L” as their separate property. This exhibit does not specifically list any of the disputed items in this matter as “separate property.” 4 Later, when Brown moved to enforce the decree, Brown’s counsel in discussing past events, referenced that “[Thomas] unilaterally moved into the separate property home of [Brown] during the divorce,” and that the superior court had previously ordered Thomas to move out the Woodinville home and granted Brown an award of attorney fees for that proceeding. Although we do not have the transcript from the dissolution trial or a subsequent proceeding that generated an award of attorney fees different than the one

-2- No. 86760-1/3

Thomas later vacated the Woodinville residence. In so doing, however, he

removed—and did not replace—several of the residence’s fixtures and several of

its major appliances, including the kitchen’s refrigerator and the washer and

dryer.

Brown later filed a motion for hearing for contempt or, in the alternative,

enforcement of the property division set forth in the decree, requesting the

replacement value of those appliances and fixtures removed by Thomas. These

items and their values, as described in her motion and as supported by

accompanying exhibits, included the following:

• The refrigerator – Exhibit C, Receipt; Exhibit D, Photo of it missing. • The washer and dryer – Exhibit E, Receipt; Exhibit F, Photo of them missing. A utility sink and cabinet was also removed. • Miniature fridge/fridge drawers (there is nothing else that could reasonably occupy this odd space) – Exhibit G, Receipt; Exhibit H, Photo of it missing. • Downstairs light fixture – Exhibit I, Photo of missing light fixture. • Two built-in bookshelves (there is not even installed carpet where they used to be) – Exhibit J, Receipt; Exhibit K, Photo of them missing. • The mirrors in the master bathroom – Exhibit L, Receipt; Exhibit M, Photo of them missing. • An entire sink/vanity from the downstairs bathroom (this same sink was already litigated at trial and Respondent was already given some sweat equity for its installation) – Exhibit N, Photo of it missing.

(Boldface omitted.) Brown also requested an award of attorney fees on the basis

that Thomas’s intransigence necessitated the filing of her motion for

before us in the instant case, we note that Thomas did not dispute these assertions at the February 2024 decree enforcement hearing.

-3- No. 86760-1/4

enforcement. Brown’s attorney later filed a declaration requesting an attorney fee

award of $7,075.50 with corresponding logs of services rendered.

Following a hearing in February 2024, a superior court commissioner

considered Brown’s request only as a motion for enforcement of the decree. The

commissioner determined that the disputed appliances and fixtures had been

awarded to Brown as part of the final divorce decree, that replacement value was

a reasonable measure of her damages, that her proposed valuations were

reasonable, and that Thomas had not proposed alternate valuations. The

commissioner therefore ordered Thomas to pay Brown a sum of $13,949.89,

which the commissioner determined was the replacement value for the missing

appliances and fixtures. The commissioner also determined that Thomas’s

conduct regarding removing fixtures and a certain appliance constituted

intransigence and granted Brown’s request for an attorney fee award of $7,075. 5

In approving of the amount of fees, but without making additional findings, the

commissioner stated that “[t]he court concludes that the fees requested are

reasonable under the circumstances.”

Thomas thereafter filed a motion for revision of the commissioner’s order,

challenging the commissioner’s determinations regarding the disputed items’

division and valuation and challenging the attorney fee award. In May 2024, the

superior court entered an order denying the motion for revision and adopting the

5 The attorney fee award requested by Brown was $7,075.50. The commissioner awarded her $7,075.00, a sum 50 cents less than that which she requested. The commissioner’s order reflects an intent to grant Brown’s award as requested but does not explain this discrepancy. Therefore, for the purpose of our decision, we treat this as a scrivener’s error and conclude that the court intended to award the sum that Brown requested.

-4- No. 86760-1/5

commissioner’s reasoning and ruling. In so doing, the court did not remand the

matter back to the commissioner to enter further findings.

Thomas timely appeals.

DISCUSSION

Preliminarily, we note that Thomas represents himself on appeal. We hold

self-represented litigants to the same standards as licensed attorneys and expect

them to follow the rules of appellate procedure. In re Marriage of Olson, 69 Wn.

App. 621, 626, 850 P.2d 527 (1993). “The scope of a given appeal is determined

by the notice of appeal, the assignments of error, and the substantive

argumentation of the parties.” Clark County v. W. Wash. Growth Mgmt. Hearings

Free access — add to your briefcase to read the full text and ask questions with AI

Related

In Re Murchison.
349 U.S. 133 (Supreme Court, 1955)
Hensley v. Eckerhart
461 U.S. 424 (Supreme Court, 1983)
Liteky v. United States
510 U.S. 540 (Supreme Court, 1994)
Fox v. Vice
131 S. Ct. 2205 (Supreme Court, 2011)
Matter of Marriage of Olson
850 P.2d 527 (Court of Appeals of Washington, 1993)
Absher Const. Co. v. KENT SCHOOL DIST.
917 P.2d 1086 (Court of Appeals of Washington, 1996)
Cowiche Canyon Conservancy v. Bosley
828 P.2d 549 (Washington Supreme Court, 1992)
Fox v. Sackman
591 P.2d 855 (Court of Appeals of Washington, 1979)
In Re the Marriage of Thompson
988 P.2d 499 (Court of Appeals of Washington, 1999)
Mahler v. Szucs
957 P.2d 632 (Washington Supreme Court, 1998)
In Re Marriage of Moody
976 P.2d 1240 (Washington Supreme Court, 1999)
Absher Construction Co. v. Kent School District No. 415
905 P.2d 1229 (Court of Appeals of Washington, 1995)
Robinson v. Robinson
225 P.2d 411 (Washington Supreme Court, 1950)
In the Matter of Marriage of Haugh
790 P.2d 1266 (Court of Appeals of Washington, 1990)
Rivard v. Rivard
451 P.2d 677 (Washington Supreme Court, 1969)
In Re Guardianship of Knutson
250 P.3d 1072 (Court of Appeals of Washington, 2011)
In Re Davis
101 P.3d 1 (Washington Supreme Court, 2004)
In Re Estate of Wright
196 P.3d 1075 (Court of Appeals of Washington, 2008)
Williams v. Williams
232 P.3d 573 (Court of Appeals of Washington, 2010)
Goodell v. Goodell
122 P.3d 929 (Court of Appeals of Washington, 2005)

Cite This Page — Counsel Stack

Bluebook (online)
Katherine Dawn Brown, V. Geoffrey Bryan Thomas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/katherine-dawn-brown-v-geoffrey-bryan-thomas-washctapp-2025.