Marriage of Deyo

Colorado Court of Appeals·Decided August 27, 2026·No. 25CA0507·Unpublished

Opinion

25CA0507 Marriage of Deyo 08-27-2026 COLORADO COURT OF APPEALS

Court of Appeals No. 25CA0507 El Paso County District Court No. 24DR803 Honorable Sarah Zane, Judge

In re the Marriage of Rachel Deyo, Appellee and Cross Appellant, and Andrew Deyo, Appellant and Cross Appellee.

JUDGMENT AFFIRMED IN PART AND REVERSED IN PART, AND CASE REMANDED WITH DIRECTIONS

Division VII

Opinion by JUDGE PAWAR

Sullivan and Meirink, JJ., concur

NOT PUBLISHED PURSUANT TO C.A.R. 35(e)

Announced August 27, 2026

Harrison Family Law, PC, Bridgette D. Harrison, Colorado Springs, Colorado, for Appellee and Cross Appellant

Mark Anthony Law, Mark Anthony Barrionuevo, Colorado Springs, Colorado, for Appellant and Cross Appellee

¶1 In this dissolution of marriage case between Rachel Deyo (wife) and Andrew Deyo (husband), husband appeals those portions of the permanent orders concerning the marital property division and maintenance. Wife cross-appeals those portions of the permanent orders concerning child support and life insurance. Husband also appeals the judgment that imposed punitive and remedial contempt sanctions against him. We reverse the marital property division, maintenance, and child support. We agree the court improperly imposed remedial contempt sanctions and therefore reverse that portion of the contempt judgment. We affirm the remainder of the contempt judgment. We remand the case for further proceedings and for the district court to address wife’s requests for life insurance and appellate attorney fees.

I. Background

¶2 In April 2024, after the parties had been separated for some time, wife petitioned to dissolve the parties’ marriage of nearly eight years. The district court entered temporary orders requiring husband to pay wife $10,000 per month in temporary maintenance. The court also ordered husband to continue paying the mortgage

associated with wife’s home but permitted him to reduce the maintenance payment by the amount of the mortgage.

¶3 In early 2025, wife sought an order of remedial and punitive contempt against husband for his failure to pay the mortgage associated with her home. The district court held a combined hearing on permanent orders and wife’s motion for contempt.

¶4 As part of its permanent orders, the district court equally divided the parties’ marital estate, which the court valued at approximately $445,000. The court included approximately $140,000 in dissipated assets to husband, finding that husband had dissipated marital assets by remodeling his own home and incurring additional debt against wife’s home.

¶5 As to wife’s contempt motion, the district court found husband in remedial and punitive contempt related to the payment of the mortgage on wife’s home. The court found that although husband had been ordered to pay the mortgage, which was a uniquely structured home equity line of credit (HELOC), husband instead allowed the HELOC to pay itself by automatically drawing down the line of credit to make the interest-only payments on the loan. As a remedial sanction, the court ordered husband to pay wife the sum

of $16,608.57, representing the HELOC payments that he should have made, or be jailed until he paid said amount. The court also fined husband $1,500 as a punitive sanction.

¶6 The court awarded wife monthly maintenance of $9,000 for an initial six months, $7,500 for the next twelve months, and $6,000 for an additional seventy-six months. Following the maintenance schedule, the court also awarded wife $2,199, $2,401, and $2,605 per month in child support.

II. Marital Property Division

¶7 Husband challenges the marital property division on multiple grounds. Because we agree that the district court erred when valuing and allocating husband’s vehicle, we reverse the marital property division and remand for further proceedings.

A. Standards of Review and Applicable Law

¶8 Upon dissolution, a district court must divide the marital property in a way that is just and equitable, although such a division need not be equal. See § 14-10-113(1), C.R.S. 2025; In re Marriage of Burford, 26 P.3d 550, 556 (Colo. App. 2001). The court enjoys broad discretion in fashioning an equitable division of marital property. In re Marriage of Balanson, 25 P.3d 28, 35 (Colo.

2001). A district court abuses its discretion when its ruling is manifestly arbitrary, unreasonable, or unfair, or when it misapplies the law. In re Marriage of Herold, 2021 COA 16, ¶ 5; cf. In re Marriage of Nelson, 2012 COA 205, ¶ 35 (Even where “there is evidence in the record that could have supported a different conclusion, we will not substitute our judgment for that of the district court.”).

¶9 While a court may not consider marital fault in dividing the marital estate, it may consider economic fault, which occurs when a spouse dissipates marital assets in contemplation of dissolution. In re Marriage of Hunt, 909 P.2d 525, 542-43 (Colo. 1995).

¶ 10 To prevent marital dissipation, an automatic temporary injunction, activated when the petition is served on the other spouse, prohibits both parties “from transferring, encumbering, concealing, or in any way disposing of, without the consent of the other party or an order of the court, any marital property, except in the usual course of business or for the necessities of life . . . .” § 14-10-107(4)(b)(I)(A), C.R.S. 2025. The temporary injunction remains in effect until the final entry of the decree, or until further order of the court. § 14-10-107(4)(b)(I). Whether a party has

violated the injunction or otherwise dissipated marital assets is a factual question for the district court to determine, see In re Marriage of Martinez, 77 P.3d 827, 830-31 (Colo. App. 2003), meaning we defer to the district court’s finding on those issues if the record supports it. In re Marriage of Gibbs, 2019 COA 104, ¶ 9.

B. Dissipation Involving Husband’s Remodel of his Home

¶ 11 We first consider and reject husband’s contention that the district court erred when it found that he dissipated funds associated with the remodel of his home and allocated those dissipated funds to him on the marital spreadsheet.

¶ 12 At the time of the permanent orders hearing, husband was living in a home valued at roughly $1.1 million that he had purchased several months before the parties’ separation. The district court found that, shortly before wife petitioned for dissolution and without wife’s consent, husband began an extensive remodel of the home that ultimately consumed over $160,000 in marital funds, charged primarily to husband’s American Express card (AMEX). The court further found that the remodel was solely for husband’s benefit and observed that husband had not even

attempted to justify the remodel, as he had provided no evidence that the remodel was necessary.

¶ 13 Accordingly, the district court found that husband had dissipated $139,000 in marital assets corresponding to the remodel expenses that he incurred after entry of the automatic temporary injunction. After adjusting to avoid double counting certain remodel expenses that husband paid using the HELOC, the court allocated husband a “marital dissipation” asset valued at $101,234.66.

¶ 14 Husband first argues that by allocating him a $101,234.66 asset on the marital spreadsheet, the court effectively awarded wife double recovery because the remodel increased the value of his home, and that increased value was divided when the court allocated the home on the marital spreadsheet. We are not persuaded.

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