Farlee v. Farlee
2012 SD 21
| S.D. | 2012Background
- Jamie and Clay Farlee married in 2003; Jamie had a preexisting inheritance (~$700,000) kept separately but used for family expenses and assets.
- During marriage, Clay expanded his ranch; Jamie managed the ranch bookkeeping and ran two home-based businesses.
- Disputes at divorce included value and marital status of assets, especially cattle, marital home on trust land, and assets traceable to Jamie’s inheritance.
- Court valued premarital cattle at $125,000 and post-marriage herd at $248,800, treating inherited property as contributing to a marital increase.
- Court recognized all property is subject to equitable division and identified need to classify assets as marital or nonmarital; several assets remained unvalued.
- Appeal challenged the court’s failure to value disputed property and to clearly classify assets, leading to remand for findings and valuations.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Valuation of disputed assets | Farlee seeks explicit valuations for all disputed items | Farlee argues valuations are sufficient to proceed | Valuation findings required; remand for complete valuations |
| Classification of marital vs nonmarital property | Inheritance-derived assets should be nonmarital | Some inheritance-derived assets may be marital | Court must definitively classify all disputed assets as marital or nonmarital |
| Cattle and premarital assets treatment | Cattle increases may be marital despite premarital ownership | Premarital herd should be given consideration but remain nonmarital | Need clear classification and valuation of cattle; ensure proper marital property treatment |
| Remand for proper equitable distribution | Without proper valuation/classification, distribution cannot be reviewed | Existing record should suffice for distribution | Remand required for findings of fact and conclusions of law on valuation and marital status |
Key Cases Cited
- Halbersma v. Halbersma, 2009 S.D. 98 (S.D. 2009) (all-property state; classify marital vs nonmarital; equal division guidance)
- Guthmiller v. Guthmiller, 670 N.W.2d 516 (S.D. 2003) (valuation required in equitable division of property)
- Guindon v. Guindon, 256 N.W.2d 894 (S.D. 1977) (all property subject to equitable division; support valuation needs)
- Midzak v. Midzak, 697 N.W.2d 733 (S.D. 2005) (properly determine status of assets before distribution)
- Endres v. Endres, 532 N.W.2d 65 (S.D. 1995) (equitable division principles and asset classification)