Marital property division; Sparks v Sparks; Fraudulent conveyance; Third-party joinder; Cassidy v Cassidy; Valuation findings; Olson v Olson; Separate property; Inheritance; Cunningham v Cunningham; Spousal support; MCL 552.23(1); Magee v Magee; Attorney fees; MCL 552.13(1); MCR 3.206(D)(2); Loutts v Loutts

The court held that the trial court did not err in rejecting plaintiff’s fraud-based challenges to the land-contract transfers, but it vacated the property division and remanded because the trial court failed to make required findings on the amount remaining from defendant’s inheritance from his mother. It also vacated the denial of spousal support and attorney fees as intertwined with the property distribution. The parties divorced after a volatile marriage involving a jointly operated salon and real estate transactions near the filing date, including conveyance of the marital home under a land contract to satisfy a claimed debt and sale of a separate property under a land contract. On appeal, the court affirmed the findings that the marital home and other property were not fraudulently transferred where promissory notes supported the debt, the notary testified plaintiff signed the quitclaim deed without duress, and the realtor testified the title company approved the transaction, and the panel deferred to the trial court’s credibility determinations. It also upheld valuation of the salon at $54,000 based on the stipulated expert business evaluation. But it concluded the judgment was defective because, despite ordering plaintiff receive one-half of whatever remained of the mother’s $550,000 funds and safe-deposit-box cash, the trial court never determined “how much, if any, remained at the time of trial” and did not make findings about the locked-box contents, requiring remand for “more specific factual findings” and vacatur of the entire property award to permit an equitable redistribution. Because “the alimony award goes hand in glove with the property distribution,” the court vacated the spousal-support ruling and directed the trial court to make specific findings under the spousal-support factors on remand. It likewise vacated the attorney-fee ruling so the trial court could revisit fees after resolving property and support and make findings tied to the parties’ financial circumstances and equities. Affirmed in part, vacated in part, and remanded.