Samuels v. Samuels

CourtSupreme Court of Delaware
DecidedMarch 17, 2025
Docket270, 2024
StatusPublished

This text of Samuels v. Samuels (Samuels v. Samuels) 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
Samuels v. Samuels, (Del. 2025).

Opinion

IN THE SUPREME COURT OF THE STATE OF DELAWARE

MARCY SAMUELS, 1 § § Respondent Below, § No. 270, 2024 Appellant, § § Court Below—Family Court v. § of the State of Delaware § WALTER SAMUELS, IV, § File No. CK22-01439 § Petition No. 22-05659 Petitioner Below, § Appellee. §

Submitted: January 10, 2025 Decided: March 17, 2025

Before SEITZ, Chief Justice; VALIHURA and TRAYNOR, Justices.

ORDER

After consideration of the parties’ briefs and the record below, it appears to

the Court that:

(1) The respondent below-appellant, Marcy Samuels (“Wife”), filed this

appeal from the Family Court’s orders addressing property division and alimony.

For the reasons set forth below, this Court affirms the Family Court’s judgment.

(2) Wife and the petitioner below-appellee, Walter Samuels, IV, were

married on November 8, 2008, legally separated on December 8, 2021, and divorced

on July 19, 2022. They had no children. The Family Court retained jurisdiction

1 The Court previously assigned pseudonyms to the parties under Supreme Court Rule 7(d). over property division, alimony, court costs, and attorneys’ fees. After a hearing,

the Family Court issued a decision deciding the ancillary matters on February 29,

2024 (“Ancillary Matters Decision”). Except as the parties had previously agreed

otherwise, the court ordered the marital estate to be equitably distributed 60/40 in

favor of Wife and Husband to pay alimony of $2,309 per month beginning on the

first day of the month after Wife’s refinancing of the marital residence or the sale of

the home to a third party.

(3) Husband moved for reargument. He argued that his monthly alimony

obligation should be reduced to $1,724 because the Family Court misapprehended

the facts concerning his $1,148 in monthly daycare expenses and should not have

eliminated those expenses from his monthly expenses. He also argued that the

Family Court should reconsider the effective date of alimony because it had

overlooked the substantial voluntary support Husband had provided to Wife while

the ancillary proceedings were pending. Wife opposed the motion.

(4) On July 2, 2024, the Family Court granted in part Husband’s motion

for reargument (“Reargument Order”). The court reduced his alimony obligation to

$1,834 after adding $949 to his monthly expenses for childcare costs. The court also

concluded that it had not fairly considered Husband’s contribution to Wife’s

household expenses between May 2022 and September 2023 and modified the

effective date of alimony to August 1, 2022 (the month after the parties divorced).

2 (5) On July 10, 2024, Wife, who had been represented by counsel in the

Family Court, filed a pro se notice of appeal in this Court. Shortly thereafter Wife

filed a pro se motion for reargument of the July 2, 2024 order in the Family Court.

The Family Court denied the motion.

(6) Wife’s arguments on appeal may be summarized as follows: (i) the

Family Court incorrectly stated that both Husband and Wife were on the deed to the

marital residence; (ii) the Court should consider bank records attached to her opening

brief, but not submitted below, to hold that the Family Court erred in determining

that a particular bank account was marital property; (iii) the Family Court erred in

finding that Husband earned approximately $101,731 a year instead of $127,780;

(iv) the Family Court erred in adding childcare expenses to Husband’s monthly

expenses; and (v) the Family Court erred in changing the effective date of alimony.

(7) This Court reviews the Family Court’s factual and legal determinations

as well as its inferences and deductions.2 We will not disturb the Family Court’s

rulings on appeal if the court’s findings of fact are supported by the record and its

explanations, deductions, and inferences are the product of an orderly and logical

2 Wife (J.F.V.) v. Husband (O.W.V., Jr.), 402 A.2d 1202, 1204 (Del. 1979). 3 reasoning process.3 We review legal rulings de novo.4 If the Family Court correctly

applied the law, then our standard of review is abuse of discretion.5

(8) We first address Wife’s contention that the Family Court incorrectly

stated that both Husband and Wife were on the deed of the marital residence.

Relying on emails exchanged by the parties in the summer of 2024, Wife also claims

that she has been unable to refinance the mortgage because she is not on the deed.

Husband admits that the Family Court erroneously described both Husband as Wife

on being the deed, but argues that this was harmless error. We agree.

(9) “When a Family Court judge misstates a fact, but the misstated fact

does not weigh significantly in his […] analysis, the misstatement is considered

harmless error.”6 In the Ancillary Matters Decision, the Family Court focused on

the matters that the parties were unable to agree upon, which did not include the

marital home. The Family Court accepted the parties’ pretrial stipulation that Wife

could retain the house if she could refinance the mortgage into her sole name and

pay Husband his share of the equity in the house, but if she was unable to do so then

the house would be sold and the net proceeds split by the property division

percentage determined by the court. The court’s factual findings concerning the

3 Id. 4 Forrester v. Forrester, 953 A.2d 175, 179 (Del. 2008) 5 CASA v. Dep’t of Servs. for Children, Youth and Their Families, 834 A.2d 63, 66 (Del. 2003). 6 Howard v. Howard, 2010 WL 5342972, at *1 (Del. Dec. 21, 2010). 4 matters that remained in dispute included a passing reference to both Husband and

Wife being on the deed for the house, but this misstatement did not affect how the

parties’ home was titled, did not change the agreement of the parties, and had no

impact on the Family Court’s resolution of the disputed issues. As to Wife’s reliance

on emails concerning the deed and her unsuccessful efforts to refinance the mortgage

in the summer of 2024, this information is beyond the scope of the record on appeal

and must be presented to the Family Court in the first instance. 7

(10) We next address Wife’s request that we consider bank records attached

to her opening brief, but not part of the record below, to hold that the Family Court

erred in determining that TD Bank account number 0138 was marital property.

Under 13 Del. C. § 1513, the Family Court has broad discretion to divide marital

property. 8 “All property acquired by either party subsequent to the marriage is

presumed to be marital property regardless of whether title is held individually or by

the parties in some form of co-ownership such as joint tenancy, tenancy in common

or tenancy by the entirety.”9 Based on Wife’s failure to provide any bank records

for TD Bank account number 0138, including documentation showing when the

account was opened, and her testimony that she regularly deposited and withdrew

7 See, e.g., Price v. Boulden, 2014 WL 3566030, at *2 (Del. July 14, 2014) (“[T]his evidence was not available to the Family Court in the first instance, is outside of the record on appeal, and cannot properly be considered by this Court.”). 8 Linder v.

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

Related

Wife (J. F. v. v. Husband (O. W. v. Jr.)
402 A.2d 1202 (Supreme Court of Delaware, 1979)
Casa v. Department of Services for Children, Youth & Their Families
834 A.2d 63 (Supreme Court of Delaware, 2003)
Forrester v. Forrester
953 A.2d 175 (Supreme Court of Delaware, 2008)
Glanden v. Quirk
128 A.3d 994 (Supreme Court of Delaware, 2015)
Lankford v. Lankford
157 A.3d 1235 (Supreme Court of Delaware, 2017)
Linder v. Linder
496 A.2d 1028 (Supreme Court of Delaware, 1985)

Cite This Page — Counsel Stack

Bluebook (online)
Samuels v. Samuels, Counsel Stack Legal Research, https://law.counselstack.com/opinion/samuels-v-samuels-del-2025.