Claudia Joan Hill Renfro v. John Malcolm Renfro, 2015-CA-00534-COA

Claudia and John Renfro divorced; chancery court initially classified 140 acres Claudia inherited as marital property and divided assets equally.
This Court (Renfro I) reversed the classification, holding the 140 acres remained Claudia’s separate property and remanded for further proceedings.
On remand, the chancery court accepted the land as Claudia’s separate property but found an equal split of the remaining, much smaller marital estate created a deficiency for John.
After applying Ferguson factors to divide property and Armstrong factors to assess alimony, the chancellor awarded John approximately $100,000 in lump-sum alimony (Claudia’s half interest in the marital home).
Claudia appealed, arguing the remand award effectively recreated the reversed property division and that the chancellor erred in awarding lump-sum alimony.
The Court of Appeals affirmed, finding the chancellor applied correct legal standards and his factual findings were supported by substantial evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the 140 acres was marital property	Claudia: land is separate inheritance, not marital	John: land had been commingled via marital labor and funds	Held separate (court accepted Renfro I and treated it as Claudia's separate property)
Whether remand permitted reconsideration of alimony	Claudia: remand limited to classification; court exceeded mandate by revisiting alimony	John: property division and alimony are intertwined; remand permits re-evaluation	Held: remand allowed reconsideration because property division and alimony are interconnected
Whether an equal division created a post-division deficit justifying alimony	Claudia: equal split was proper; John had no unmet need (cohabiting)	John: equal split left insufficient assets and income for his future security	Held: chancellor found a deficiency for John; substantial evidence supports that finding
Whether lump-sum alimony award was appropriate and supported by law	Claudia: award effectively recreates reversed division; factual findings on income/need were flawed	John: Armstrong factors support lump-sum alimony to remedy deficiency	Held: Armstrong analysis applied; chancellor acted within discretion and award affirmed

Ferguson v. Ferguson, 639 So. 2d 921 (Miss. 1994) (sets factors for equitable division of marital property)
Armstrong v. Armstrong, 618 So. 2d 1278 (Miss. 1993) (lists factors for awarding alimony)
Lewis v. Pagel, 172 So. 3d 162 (Miss. 2015) (confirms Armstrong factors apply when assessing alimony)
Yelverton v. Yelverton, 961 So. 2d 19 (Miss. 2007) (standard of appellate review in divorce cases: substantial evidence/manifest error)
Carambat v. Carambat, 72 So. 3d 505 (Miss. 2011) (appellate review: factual findings not disturbed unless manifestly wrong)