Divorce; Third-party property interests; Cassidy v Cassidy; Standing; Reed v Reed; Property division; Equitable distribution; Sparks v Sparks; Factual findings; Butler v Simmons-Butler

The court held that defendant-ex-husband was not entitled to relief based on the trial court’s treatment of a nonparty’s claimed interest in a condominium, but remand was required because the trial court failed to make adequate findings supporting the property division. The parties divorced after a lengthy marriage, and the judgment awarded plaintiff-ex-wife the Garrison condominium and Lebanon property, while awarding defendant his businesses and associated assets and debts. On appeal, the court first rejected defendant’s argument that the divorce court lacked subject-matter jurisdiction to eliminate the nonparty’s interest in the Garrison condominium. Although divorce courts generally may determine only “‘the rights and obligations between the husband and wife, to the exclusion of third parties,’” the court held that defendant could not obtain appellate relief because “a litigant must assert his or her own legal rights and interests” and may not seek relief based on a third party’s rights. The court next held that remand was required on the property division because the trial court “did not explain how its property distribution was equitable.” The trial court merely divided the property “without any discussion of relative values” and only “implied” that the division was equitable. Relying on Sparks and Butler, the court held that this was insufficient because a divorce court must make “specific findings of fact justifying and explaining its decision” to permit meaningful appellate review. Remanded.