Mark Walsh v. Jennifer Walsh

CourtSupreme Court of Delaware
DecidedApril 6, 2026
Docket316, 2025
StatusPublished

This text of Mark Walsh v. Jennifer Walsh (Mark Walsh v. Jennifer Walsh) 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
Mark Walsh v. Jennifer Walsh, (Del. 2026).

Opinion

IN THE SUPREME COURT OF THE STATE OF DELAWARE

MARK WALSH,1 § § No. 316, 2025 Petitioner Below, § Appellant, § Court Below–Family Court § of the State of Delaware v. § § File No. CK21-03133 JENNIFER WALSH, § Petition No. 22-05692 § Respondent Below, § Appellee. §

Submitted: January 9, 2026 Decided: April 6, 2026

Before TRAYNOR, GRIFFITHS, and LEGROW, Justices.

ORDER

After consideration of the parties’ briefs and the Family Court record, it

appears to the Court that:

(1) Mark Walsh (“Ex-Husband”) appeals the Family Court’s order

resolving matters ancillary to his divorce from Jennifer Walsh (“Ex-Wife”). After

careful review of the parties’ arguments, we affirm the Family Court’s judgment.

(2) The record reflects that the parties married on March 18, 2001. In

March 2022, Ex-Husband petitioned for divorce, and the Family Court entered a

divorce decree on August 23, 2022. At the parties’ request, the court retained

1 The Court previously assigned pseudonyms to the parties under Supreme Court Rule 7(d). jurisdiction over ancillary matters. Following an evidentiary hearing, the Family

Court issued a written decision on May 16, 2025. Among other things, the Family

Court: (i) instructed the parties to sell the marital home and divide the proceeds

equally, (ii) ordered that the parties’ marital assets and debts be split 50/50, and (iii)

awarded Ex-Wife permanent alimony in the amount of $970.00 per month. Ex-

Husband filed a timely motion for reargument, which the Family Court denied. Ex-

Husband appeals.

(3) This Court’s review of an appeal from the Family Court extends to a

review of the law and the facts, as well as a review of the inferences and deductions

made by the trial judge.2 We will not disturb findings of fact unless they are clearly

wrong and justice requires that they be overturned.3 We review errors of law de

novo.4 If the Family Court has correctly applied the law, our standard of review is

abuse of discretion.5 When the determination of facts turns on the credibility of

witnesses, this Court will not substitute its opinion for that of the trial judge.6

(4) Ex-Husband raises five claims of error on appeal: (i) the Family Court

violated his due process rights when it denied his request for a continuance of the

evidentiary hearing, (ii) the Family Court abused its discretion by ordering the sale

2 Wife (J.F.V.) v. Husband (O.W.V., Jr.), 402 A.2d 1202, 1204 (Del. 1979). 3 Forrester v. Forrester, 953 A.2d 175, 179 (Del. 2008). 4 Smart v. Smart, 2015 WL 1530898, at *4 (Del. Apr. 6, 2015). 5 Id. 6 Greene v. Greene, 105 A.3d 989, 2014 WL 7010738, at *1 (Del. Nov. 25, 2014) (TABLE). 2 of the marital home without considering equitable alternatives, (iii) the Family Court

improperly ordered the division of Ex-Husband’s 401K plan but not the division of

Ex-Wife’s 401K plan, (iv) the Family Court’s valuation of the parties’ motor

vehicles was not supported by the evidence, and (v) the Family Court erred when it

awarded Ex-Wife permanent alimony. We address Ex-Husband’s arguments in turn.

(5) Ex-Husband first argues that the Family Court erred when it denied his

request for a continuance. The record reflects that the February 27, 2025 trial date

was the fifth trial date scheduled in this matter. Trial was originally scheduled for

June 5, 2023. In May 2023, the parties stipulated to a continuance of the trial, and

the matter was rescheduled to November 15, 2023. Following an October 2023

teleconference with the parties, the court concluded that the parties would not be

ready for trial in November because of outstanding discovery issues. The Family

Court therefore set a new trial date of April 12, 2024. For reasons not entirely clear

from the record, that trial date was later moved to October 1, 2024. After a case

management conference held in September 2024, trial was rescheduled to February

27, 2025. Notably, Ex-Husband was represented by counsel from the filing of his

petition for divorce in March 2022 until January 16, 2025, when counsel moved to

withdraw. During this time, the parties exchanged discovery and engaged in motion

practice related to their respective discovery requests. On January 29, 2025, Ex-

Husband, proceeding pro se, moved for a continuance, citing his desire to retain new

3 counsel. On February 13, the Family Court granted counsel’s motion to withdraw

and denied Ex-Husband’s motion for a continuance.7

(6) We review the Family Court’s denial of a motion for a continuance for

an abuse of discretion.8 Here, Ex-Husband does not dispute that he had notice of the

February 27 trial date, and the record reflects that he had more than ample time to

prepare for trial.9 Moreover, as noted above, Ex-Husband and Ex-Wife exchanged

discovery and resolved their discovery disputes through motion practice in the

months preceding the trial, which took place almost three years after the parties’

divorce. “Trial judges are vested with the discretion to resolve scheduling matters

and to control their own docket.”10 Under the circumstances, we conclude that the

Family Court acted within its discretion when it denied Ex-Husband’s request for

another continuance.

(7) Ex-Husband next argues that the Family Court abused its discretion by

ordering the sale of the marital property without considering whether Ex-Husband

could buy out Ex-Wife’s interest in the property or the “competent appraisal

7 On February 20, apparently unaware that the Family Court had granted his motion to withdraw, Ex-Husband’s former counsel filed a motion to withdraw his motion to withdraw together with a motion for a continuance. Following the February 27 trial, the Family Court found these motions to be moot—counsel’s motion to withdraw had been granted and the evidentiary hearing had proceeded as scheduled. 8 Stevenson v. Simons, 905 A.2d 747, 2006 WL 2048487, at *2 (Del. July 21, 2006) (TABLE). 9 See Tsipouras v. Tsipouras, 677 A.2d 493, 496 (Del. 1996) (noting that procedural due process requires that parties whose rights are to be affected by the proceedings are entitled to notice and an opportunity to be heard). 10 Americas Mining Corp. v. Theriault, 51 A.3d 1213, 1238 (Del. 2012). 4 evidence.”11 The record belies Ex-Husband’s contention concerning the sale of the

marital property. Although Ex-Husband and Ex-Wife each attempted to introduce

at trial a real estate appraisal of the marital home, Ex-Husband’s real estate

appraiser—Kendall Dixon—testified that both appraisals were performed more than

two years ago and therefore could not be relied upon. The trial court therefore

properly refused to consider the appraisals when determining the value of the marital

home. Absent the parties’ agreement as to value, the court was simply unable to

assign a monetary value to the home without ordering its sale. We also note that,

contrary to Ex-Husband’s claim on appeal, the Family Court repeatedly asked Ex-

Husband if he was willing to buy out Ex-Wife’s share of the home (albeit, using Ex-

Wife’s higher appraisal as the basis for negotiation),12 and Ex-Husband told the court

that he was unwilling to do so.

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Related

Wife (J. F. v. v. Husband (O. W. v. Jr.)
402 A.2d 1202 (Supreme Court of Delaware, 1979)
Tsipouras v. Tsipouras
677 A.2d 493 (Supreme Court of Delaware, 1996)
Forrester v. Forrester
953 A.2d 175 (Supreme Court of Delaware, 2008)
Glanden v. Quirk
128 A.3d 994 (Supreme Court of Delaware, 2015)
Americas Mining Corp. v. Theriault
51 A.3d 1213 (Supreme Court of Delaware, 2012)

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