Walsh v. Walsh

CourtCourt of Appeals of North Carolina
DecidedJuly 16, 2025
Docket24-869
StatusUnpublished

This text of Walsh v. Walsh (Walsh v. Walsh) 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
Walsh v. Walsh, (N.C. Ct. App. 2025).

Opinion

An unpublished opinion of the North Carolina Court of Appeals does not constitute controlling legal authority. Citation is disfavored, but may be permitted in accordance with the provisions of Rule 30(e)(3) of the North Carolina Rules of Appellate Procedure.

IN THE COURT OF APPEALS OF NORTH CAROLINA

No. COA24-869

Filed 16 July 2025

Granville County, No. 22CVD000674-380

SARA WALSH, Plaintiff,

v.

BENJAMIN WALSH, Defendant.

Appeal by defendant from order entered 4 March 2024 by Judge Caroline S.

Burnette in Granville County District Court. Heard in the Court of Appeals 22 April

2025.

Raleigh Divorce Law Firm, by Jennifer Sinclair Simpkins and Xavier J. McLean, for plaintiff-appellee.

Scott Allen for defendant-appellant.

ZACHARY, Judge.

Defendant Benjamin Walsh appeals from the trial court’s equitable

distribution order. After careful review, we affirm in part, reverse in part, and

remand.

I. Background

Plaintiff Sara Walsh and Defendant married in 2015 and separated in 2022. WALSH V. WALSH

Opinion of the Court

On 10 February 2023, Plaintiff filed a complaint for equitable distribution in

Granville County District Court. Defendant filed his answer and counterclaim on 5

May 2023.1 Both parties sought an unequal distribution of property in their own

favor.

On 28 November 2023, the trial court entered a final pretrial order containing

the parties’ stipulations. These stipulations included agreements concerning the

classification and valuation of various real and personal property, and the parties’

determinations as to how it should be distributed.

The equitable distribution matter came on for hearing in Granville County

District Court on 21 February 2024. On 4 March 2024, the trial court entered an

equitable distribution order. In its order, the court determined that “[a]n equal

division is equitable in this matter” and made various findings regarding the

classification, valuation, and distribution of the parties’ real and personal property.

Among other things, the court ordered that Defendant refinance the mortgages on

the marital residence “into his sole and separate name” and pay a distributive award

of $447,502.32 to Plaintiff at the closings of the refinances. If Defendant were unable

to refinance the mortgages, the court ordered that the residence be listed for sale

either until it sold or the parties agreed otherwise in writing.

1By a consent order entered on 16 May 2023, this matter was consolidated with related actions, including those concerning custody, child support, and attorney’s fees. By the time of the equitable distribution order’s filing, the issues of custody and child support had been resolved.

-2- WALSH V. WALSH

Defendant timely filed notice of appeal from the trial court’s order.

II. Discussion

Defendant raises several arguments on appeal from the equitable distribution

order. Principally, he argues that the trial court made various errors in calculating

the distribution and improperly made an unequal distribution to Plaintiff without

finding that an unequal distribution would be equitable. Plaintiff acknowledges that

remand is necessary to address these issues, and we agree.

Defendant also argues that although the trial court is tasked with valuing

marital property as of the date of separation, in the case at bar, no competent evidence

supports the court’s valuations of the marital residence and three pieces of business

property as of the date of separation. Finally, Defendant contends that the court erred

by “ordering the marital residence to be sold and the mortgages to be refinanced when

the parties stipulated that the mortgages and marital residence would be distributed

to Defendant.” With respect to these issues, we disagree.

A. Standard of Review

This Court reviews an equitable distribution order to determine whether

“there is competent evidence to support the trial court’s findings of fact and whether

the findings support the conclusions of law and ensuing judgment. The trial court’s

findings of fact are binding on appeal as long as competent evidence supports them,

despite the existence of evidence to the contrary.” Klein v. Klein, 290 N.C. App. 570,

577, 892 S.E.2d 894, 903 (2023) (citation omitted).

-3- WALSH V. WALSH

“A trial court is vested with wide discretion in family law cases, including

equitable distribution cases. Accordingly, a trial court’s ruling in an equitable

distribution award will be disturbed only if it is so arbitrary that it could not have

been the result of a reasoned decision.” Id. at 577–78, 892 S.E.2d at 903 (cleaned up).

“Only a finding that the judgment was unsupported by reason and could not have

been a result of competent inquiry, or a finding that the trial judge failed to comply

with the statute, will establish an abuse of discretion.” Id. at 578, 892 S.E.2d at 903

(citation omitted).

B. Analysis

Equitable distribution is governed by N.C. Gen. Stat. § 50-20, which sets forth

“a three-step process; the trial court must (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.” Id. (citation omitted); N.C. Gen. Stat. § 50-20 (2023). “Furthermore,

in doing all these things the court must be specific and detailed enough to enable a

reviewing court to determine what was done and its correctness.” Klein, 290 N.C.

App. at 578, 892 S.E.2d at 903 (citation omitted).

This appeal does not concern the classification step; Defendant’s issues arise

from the valuation and distribution steps of the process. We thus begin with

Defendant’s arguments concerning valuation and then proceed to his distribution

claims.

1. Valuation

-4- WALSH V. WALSH

“For purposes of equitable distribution, marital property shall be valued as of

the date of the separation of the parties, and evidence of . . . postseparation

occurrences or values is competent as corroborative evidence of the value of marital

property as of the date of the separation of the parties.” N.C. Gen. Stat. § 50-21(b).

“In an equitable distribution proceeding, the trial court is to determine the net fair

market value of the property based on the evidence offered by the parties.” Fitzgerald

v. Fitzgerald, 161 N.C. App. 414, 419, 588 S.E.2d 517, 521 (2003) (citation omitted).

a. Marital Residence

Defendant first contends that no competent evidence supports the trial court’s

valuation of the marital residence as $650,000.00 on the date of separation because

the only valuation evidence presented by the parties was an appraisal that

established the $650,000.00 value on 7 December 2023, approximately 15 months

after the date of separation.

Defendant likens this case to Fitzgerald, in which “the only evidence presented

on the value of the house were two appraisals valuing the house at $395,000.00, one

performed over a year after the parties’ separation and one performed more than

three years after the separation.” Id. This Court reversed the trial court’s date-of-

separation valuation of the house, noting that “[n]othing in the findings of the trial

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Fitzgerald v. Fitzgerald
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Despathy v. Despathy
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Atkins v. Atkins
401 S.E.2d 784 (Court of Appeals of North Carolina, 1991)
Grasty v. Grasty
482 S.E.2d 752 (Court of Appeals of North Carolina, 1997)
Lund v. Lund
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Clemons v. Clemons
828 S.E.2d 501 (Court of Appeals of North Carolina, 2019)

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Walsh v. Walsh, Counsel Stack Legal Research, https://law.counselstack.com/opinion/walsh-v-walsh-ncctapp-2025.