The Appellate Group

Holt v. Holt

Holt v. Holt, 2024 UT App 6 (Orme, J.)


A divorce decree awarded Ex-Wife a commercial property and Ex-Husband an equity interest in the property redeemable “when the property is sold.” For years, Ex-Wife did not sell the property. The district court denied Ex-Husband’s petition to require Ex-Wife to sell. The Court of Appeals reversed, holding in part:

  • A reasonable time for performance will be implied if a contract fails to include a specific time for performance.
  • Practice Tip: Parties should include in the appellate record transcripts from all relevant proceedings. Appellate courts will often rely on a proceeding’s minutes if the transcript is not included in the record.

Read the full court opinion