Goodwin v. Goodwin
2016 Ark. App. 585
| Ark. Ct. App. | 2016Background
- Ryan and Stephanie Goodwin married in 2004, acquired a gold-coin collection during the marriage, and separated in 2012; divorce decree (Apr. 29, 2014) required the coins be divided equally.
- Stephanie later alleged Ryan had withheld or sold coins after the decree; she received only 28–29 coins at separation.
- Documentary evidence introduced by Stephanie (purchase invoices, sales receipts, spreadsheet) showed purchases of about 161–162 coins and sales of 12–16 coins through Swiss America.
- Ryan testified he sold roughly 70 coins at shows (without documentary proof), moved remaining coins to others’ houses, and claimed he had given Stephanie her share.
- The circuit court found 129 coins existed at separation (excluding children’s 11), Stephanie received 29, and Ryan failed to give her half; it awarded Stephanie $45,007.96 (value based on Stephanie’s evidence) and held Ryan in civil contempt.
- Ryan appealed, arguing (1) the court lacked authority under Ark. R. Civ. P. 60(c) to modify the decree after 90 days and (2) the contempt finding was against the preponderance of the evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the court erred under Ark. R. Civ. P. 60(c) in ordering payment for unequal division after 90 days | Stephanie: court may enforce divorce decree and punish contempt for noncompliance | Ryan: post-decree monetary order was an improper modification beyond 90-day Rule 60(c) window | Court: not a Rule 60(c) modification; order enforced decree via civil contempt — affirmed |
| Whether clear preponderance supports contempt finding that Ryan withheld coins | Stephanie: documentary evidence and testimony show ~162 coins acquired, 12–16 sold, she received only 29; valuation supports award | Ryan: he sold ~70 coins and gave Stephanie her share; no contempt | Court: trial judge credited Stephanie, Ryan offered no documentary proof of additional sales; contempt finding not against preponderance — affirmed |
| Whether valuation of coins was unsupported by evidence | Stephanie: introduced purchase/sale documentation allowing per-coin valuation | Ryan: argued no admissible evidence of coin value | Court: used documentary evidence submitted by Stephanie to compute per-coin average — valuation upheld |
| Standard of review for contempt findings | N/A | N/A | Appellate court defers to circuit court on credibility; reversal only if clearly against preponderance of evidence |
Key Cases Cited
- Williams v. Arnold, 479 S.W.3d 56 (Ark. App. 2015) (standard for reversing civil-contempt findings: reverse only if clearly against preponderance)
- Russell v. Russell, 430 S.W.3d 15 (Ark. 2013) (appellate deference to trial court credibility determinations)
