Godfrey v. Godfrey
Godfrey v. Godfrey, 2024 UT App 156 (Christiansen Forster, J.)
Family Law
Husband and Wife divorced. After a bench trial, Husband appealed various aspects of the court’s rulings, including (1) updated home appraisal and expert testimony, (2) valuing the properties at the time of trial, (3) calculating Wife’s income, (4) awarding Wife half of the proceeds of Husband’s business, and (5) division of a savings account. The Utah Court of Appeals affirmed, holding:
- The district court did not abuse its discretion in its rulings, and Husband did not preserve the last issue.
- Practice tip: In a footnote, the court noted it has “inconsistently articulated the standard of review to be applied when reviewing a trial court’s determination that property is marital or separate.” It noted the “question does warrant additional consideration.”