Marriage of Palominos Correa

CourtColorado Court of Appeals
DecidedMarch 5, 2026
Docket24CA2196
StatusUnpublished

This text of Marriage of Palominos Correa (Marriage of Palominos Correa) is published on Counsel Stack Legal Research, covering Colorado Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Marriage of Palominos Correa, (Colo. Ct. App. 2026).

Opinion

24CA2196 Marriage of Palominos Correa 03-05-2026

COLORADO COURT OF APPEALS

Court of Appeals No. 24CA2196 Arapahoe County District Court No. 23DR30495 Honorable Michelle Jones, Judge

In re the Marriage of

Daniel Palominos Correa,

Appellee,

and

Carolina Aranis Jimenez,

Appellant.

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

Division VII Opinion by JUDGE LUM Tow and Moultrie, JJ., concur

NOT PUBLISHED PURSUANT TO C.A.R. 35(e) Announced March 5, 2026

Daniel Palominos Correa, Pro Se

Ian Griffin, Aurora, Colorado, for Appellant ¶1 In this dissolution of marriage case between Carolina Aranis

Jimenez (wife) and Daniel Palominos Correa (husband), wife appeals

the portions of the permanent orders concerning the property

division. We affirm in part and reverse in part the district court’s

permanent orders and remand the case for further proceedings.

I. Background

¶2 The parties married in 2013 in Santiago, Chile. Notably, the

parties’ Chilean marriage certificate stated that they “agreed to a

total separation of assets” marriage. At the permanent orders

hearing, two witnesses with expertise in Chilean matrimonial law1

testified that this meant the parties “elect[ed] to have their property

treated separately” and that a Chilean court would award the

property to the party in whose name the property was titled.

¶3 After they married, the parties lived in Chile for several years.

During that time, they purchased six apartments in Chile, all of

which were titled in wife’s name only (the disputed Chilean

apartments). The parties then moved to Colorado at some point

1 One of the expert witnesses represented wife in the Chilean

divorce proceedings; the other was related to wife. The court accepted the witnesses as experts over husband’s objection. Husband doesn’t appeal the court’s decision.

1 between 2018 and 2020. Thereafter, they purchased a home and a

timeshare, both of which were jointly titled.

¶4 In April 2023, husband filed a petition for dissolution of

marriage. The district court held a permanent orders hearing in

September 2024. At the hearing, wife argued that the parties’

Chilean marriage certificate constituted a valid agreement to keep

any asset titled in one party’s name separate, even if the asset was

purchased during the parties’ marriage. Thus, she argued that all

six disputed Chilean apartments were her separate property and

should not be included in the court’s division of the marital estate.

In contrast, husband argued that the Chilean marriage certificate

was not a valid agreement and that the disputed Chilean

apartments were marital property because they were purchased

during the parties’ marriage.

¶5 At the end of the hearing, the court dissolved the parties’

marriage. The court later entered permanent orders. It found, as

relevant here, that the disputed Chilean apartments were marital

property. It also excluded a 2013 Mercedes from the marital estate,

finding that husband had sold the vehicle to a relative. The court

then valued the parties’ property and distributed it, awarding wife

2 $469,739, or roughly 51%, of the marital estate, which included one

vehicle and all six disputed Chilean apartments. The court

awarded husband $442,780, or roughly 49% of the marital estate,

which included one vehicle, the parties’ marital home, and their

timeshare.

¶6 On appeal, wife contends that the district court made several

errors in dividing the parties’ marital property. Specifically, she

argues that the court erred by (1) finding that the disputed Chilean

apartments were marital; (2) excluding the 2013 Mercedes from the

marital estate; and (3) miscalculating the value of several of the

parties’ assets.

II. Property Division Framework and Standard of Review

¶7 A district court has great latitude in equitably dividing a

marital estate in such proportions as it deems just. See § 14-10-

113(1), C.R.S. 2025; In re Marriage of Medeiros, 2023 COA 42M,

¶ 28. Before dividing a marital estate, a court must determine

whether an asset is marital and subject to division, or whether it is

separate and not subject to division. § 14-10-113(1); see Medeiros,

¶ 49; In re Marriage of Cardona, 2014 CO 3, ¶ 12. Then, it must

value the property as of the date of the decree or the date of the

3 hearing on disposition of property if such hearing precedes the date

of the decree. § 14-10-113(5); Cardona, ¶ 12.

¶8 In equitably distributing the marital property, the district

court must consider all relevant factors, including the contributions

of each spouse; the value of the property set apart to each spouse;

the economic circumstances of each spouse; and any increase,

decrease, or depletion in the value of any separate property during

the marriage. § 14-10-113(1)(a)-(d); In re Marriage of Balanson, 25

P.3d 28, 35 (Colo. 2001). The overall property division must be

equitable, but it does not have to be equal. In re Marriage of Wright,

2020 COA 11, ¶ 3. “The key to an equitable distribution is

fairness,” which depends on the facts and circumstances of each

case. Id. (quoting In re Marriage of Gallo, 752 P.2d 47, 55 (Colo.

1988)).

¶9 Determining how to weigh the relevant factors and equitably

divide the marital estate is within the district court’s sound

discretion, and we won’t disturb a court’s property division orders

absent a showing that it abused that discretion. In re Marriage of

Smith, 2024 COA 95, ¶¶ 64, 67. A court abuses its discretion when

its decision is manifestly arbitrary, unreasonable, or unfair, or

4 based on a misapplication of the law. Id. at ¶ 65. We review the

court’s application of the law de novo. C & C Invs., LP v. Hummel,

2022 COA 42, ¶ 29; see Lewis v. Lewis, 189 P.3d 1134, 1141 (Colo.

2008).

III. Determination that the Chilean Apartments Were Marital Property

¶ 10 Wife first contends that the district court erred by determining

that the disputed Chilean apartments were marital property rather

than her separate property. To get there, she argues that the court

erred by failing to apply Chilean law to determine whether the

parties’ Chilean marriage certificate constituted a “valid agreement”

under section 14-10-113(2)(d). She asserts that under Colorado’s

choice-of-law approach, the court should have applied Chilean law

to determine whether the agreement was “valid.” And she points

out that at the permanent orders hearing, two expert witnesses

testified that under Chilean law, the parties’ marriage certificate

would be treated as a valid agreement to keep their individually

titled property separate.

¶ 11 We agree that the district court erred by failing to conduct a

choice-of-law analysis before determining whether the parties’

5 marriage certificate was a “valid agreement” under section 14-10-

113(2)(d). But, as explained below, we don’t have enough

information to determine whether the court erred by ultimately

applying Colorado’s substantive law to evaluate the validity of the

agreement.

A. The “Valid Agreement” Exception

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