Mosiello v. Mosiello

CourtCourt of Appeals of North Carolina
DecidedSeptember 20, 2022
Docket21-734
StatusPublished

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

Bluebook
Mosiello v. Mosiello, (N.C. Ct. App. 2022).

Opinion

IN THE COURT OF APPEALS OF NORTH CAROLINA

2022-NCCOA-626

No. COA21-734

Filed 20 September 2022

Union County, No. 18 CVD115

MELISSA MOSIELLO, Plaintiff,

v.

ANTHONY MOSIELLO, Defendant.

Appeal by defendant from judgment entered 28 June 2021 by Judge William

F. Helms in Union County District Court. Heard in the Court of Appeals 24 August

2022.

Leitner, Bragg & Griffin, PLLC, by Jordan M. Griffin, for plaintiff appellee.

Plumides, Romano & Johnson, PC, by Richard B. Johnson, for defendant- appellant.

TYSON, Judge.

¶1 Anthony Mosiello (“Anthony”) appeals from an order granting an unequal

distribution of marital property to his ex-wife, Melissa Mosiello (“Melissa”). We

affirm.

I. Background

¶2 Anthony and Melissa married on 4 September 1992. Both parties remained

uncertain about the official date of separation during the equitable distribution MOSIELLO V. MOSIELLO

Opinion of the Court

hearing. When the divorce hearing was held over one year later, the trial court found

the parties had separated on 9 March 2009. The trial court entered a Judgment of

Divorce on the same day as the divorce hearing, 5 April 2021. Melissa’s claim for

equitable distribution was heard on 10 March 2020. The trial court took the matter

under advisement and entered a written order on 28 June 2021. The trial court

concluded an unequal division would be equitable. Anthony filed a timely appeal.

II. Jurisdiction

¶3 This Court possesses appellate jurisdiction over equitable distribution orders

“if the order or judgment would otherwise be a final order or judgment.” N.C. Gen.

Stat. § 50-19.1 (2021); see also N.C. Gen. Stat. § 7A-27(b)(2) (2021).

III. Issues

¶4 Anthony argues the trial court: (1) abused its discretion when determining

whether an equal distribution of the marital estate was not equitable; (2) failed to

rely on sufficient evidence to support its finding of facts; and, (3) prejudiced him by

delaying entry of the order.

IV. Unequal Distribution of Marital Property

¶5 The trial court found an unequal distribution of marital property was equitable

in this case. Anthony argues the trial court abused its discretion by distributing the

most substantial marital asset, the marital home valued at $153,000, to Melissa.

A. Standard of Review MOSIELLO V. MOSIELLO

¶6 Trial courts are accorded discretion when distributing marital property, and

“the exercise of that discretion will not be disturbed in the absence of clear abuse.”

McNeely v. McNeely, 195 N.C. App. 705, 709, 673 S.E.2d 778, 781 (2009) (citation and

quotations omitted). “A ruling committed to a trial court’s discretion is to be accorded

great deference and will be upset only upon a showing that it was so arbitrary that it

could not have been the result of a reasoned decision.” White v. White, 312 N.C. 770,

777, 324 S.E.2d 829, 833 (1985). “Once the trial court decides that an unequal

division of the marital property would be equitable, its decision will only be reversed

for an abuse of discretion.” Albritton v. Albritton, 109 N.C. App. 36, 42, 426 S.E.2d

80, 84 (1993) (citing White, 312 N.C. at 777, 324 S.E.2d at 833).

B. Analysis

¶7 N.C. Gen. Stat. § 50-20 (2021) governs the distribution of marital and divisible

property. “[E]quitable distribution is a three-step process requiring the trial court to

(1) determine what is marital [and divisible] property; (2) find the net value of the

property; and, (3) make an equitable distribution of that property.” Petty v. Petty, 199

N.C. App. 192, 197, 680 S.E.2d 894, 898 (2009) (citations and quotations omitted).

¶8 Trial courts are mandated by statute to divide marital property equally “unless

the court determines that an equal division is not equitable.” N.C. Gen. Stat. § 50-

20(c). If the trial court determines “an equal division is not equitable, the court shall

divide the marital property and divisible property equitably” and “consider all of the MOSIELLO V. MOSIELLO

following factors under [N.C. Gen. Stat. § 50-20(c)(1)-(12)].” Id.; see also White, 312

N.C. at 776-77, 324 S.E.2d at 832-33 (explaining that “if no evidence is admitted

tending to show that an equal division would be inequitable, the trial court must

divide the marital property equally”).

¶9 When determining whether an unequal distribution is equitable, the trial court

must make written findings of fact demonstrating and adjudicating which relevant

and admitted evidence supports the N.C. Gen. Stat. § 50-20(c) distributional factors

the court considered. Daetwyler v. Daetwyler, 130 N.C. App. 246, 249, 502 S.E.2d 662,

665 (1998) (citation omitted). “The trial court need not make ‘exhaustive’ findings of

the evidentiary facts, but must include the ‘ultimate’ facts considered.” Id. (quoting

Armstrong v. Armstrong, 322 N.C. 396, 405–06, 368 S.E.2d 595, 600 (1988)).

¶ 10 If a party presents evidence that an unequal distribution is not equitable under

one or more of the N.C. Gen. Stat. § 50-20(c) factors, the trial court must exercise its

discretion when assessing and adjudicating how much weight to give each factor.

White, 312 N.C. at 776-77, 324 S.E.2d at 832-33 (explaining that when “evidence

tending to show that an equal division of marital property would not be equitable is

admitted, . . . the trial court must exercise its discretion in assigning the weight

[accorded to] each factor”). “[T]he trial court is not required to show how it balanced

the factors; the weight given to each factor is in the trial court’s discretion; and there

is no need to show exactly how the trial court arrived at its decision regarding unequal MOSIELLO V. MOSIELLO

division,” but an appellate court must be able to review and conclude the statutory

factors were followed. Montague v. Montague, 238 N.C. App. 61, 70-71, 767 S.E.2d 71,

78 (2014) (citation omitted).

¶ 11 “A single distributional factor may support an unequal division.” Mugno v.

Mugno, 205 N.C. App. 273, 278, 695 S.E.2d 495, 499 (2010) (citation omitted); see also

Leighow v. Leighow, 120 N.C. App. 619, 463 S.E.2d 290 (1995) (finding three

distributional factors in favor of one spouse supported an unequal distribution order).

Our Supreme Court has held “a party’s misconduct during the marriage which

dissipates or reduces the value of the marital assets for non-marital purposes can be

considered under [factor (12) of] N.C. Gen. Stat. § 50–20(c)(12) in determining

whether equal would be equitable.” Coleman v. Coleman, 89 N.C. App. 107, 109-110,

365 S.E.2d 178, 180 (1988) (citing Smith v. Smith, 314 N.C. 80, 81, 331 S.E.2d 682,

683 (1985)).

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Related

White v. White
324 S.E.2d 829 (Supreme Court of North Carolina, 1985)
Smith v. Smith
331 S.E.2d 682 (Supreme Court of North Carolina, 1985)
Coleman v. Coleman
365 S.E.2d 178 (Court of Appeals of North Carolina, 1988)
Loving v. Loving
455 S.E.2d 885 (Court of Appeals of North Carolina, 1995)
Mishler v. Mishler
367 S.E.2d 385 (Court of Appeals of North Carolina, 1988)
Daetwyler v. Daetwyler
502 S.E.2d 662 (Court of Appeals of North Carolina, 1998)
Petty v. Petty
680 S.E.2d 894 (Court of Appeals of North Carolina, 2009)
McNeely v. McNeely
673 S.E.2d 778 (Court of Appeals of North Carolina, 2009)
Armstrong v. Armstrong
368 S.E.2d 595 (Supreme Court of North Carolina, 1988)
Albritton v. Albritton
426 S.E.2d 80 (Court of Appeals of North Carolina, 1993)
Nye v. Nye
396 S.E.2d 91 (Court of Appeals of North Carolina, 1990)
Wall v. Wall
536 S.E.2d 647 (Court of Appeals of North Carolina, 2000)
Leighow v. Leighow
463 S.E.2d 290 (Court of Appeals of North Carolina, 1995)
Britt v. Britt
606 S.E.2d 910 (Court of Appeals of North Carolina, 2005)
Troutman v. Troutman
667 S.E.2d 506 (Court of Appeals of North Carolina, 2008)
McLean v. McLean
363 S.E.2d 95 (Court of Appeals of North Carolina, 1987)
Lawing v. Lawing
344 S.E.2d 100 (Court of Appeals of North Carolina, 1986)
Mugno v. Mugno
695 S.E.2d 495 (Court of Appeals of North Carolina, 2010)
Mrozek v. Mrozek
496 S.E.2d 836 (Court of Appeals of North Carolina, 1998)
Alexander v. Alexander
315 S.E.2d 772 (Court of Appeals of North Carolina, 1984)

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