Green v. Green, 69 A.3d 282

Husband and Wife divorced after 1981 marriage; December 2008 divorce decree and a December 29, 2008 order memorialized a 50/50 distribution based on a handwritten Exhibit 1 listing assets and values; no formal trial occurred.
Parties agreed to transfer real estate and investment accounts and exchange personal property following a 2009 status conference; a 2009 order stated disputes over personal property would be resolved within 30 days or hearing could be requested.
April 2010 order affirmed the earlier 2009 order, concluding personal property distribution was complete; no post-trial relief was sought.
February 10, 2011 Husband moved to Enforce the Marital Settlement Agreement; the trial court noted the agreement was not a formal written MSA but that it was an order of court and opened the record for trial aids.
The court subsequently allowed trial aids and held a July 25, 2011 hearing; September 23, 2011 order followed, prompting Husband’s appeal.
The Pennsylvania Superior Court affirmed, concluding the challenges to Exhibit 1 and the trial aids were waived or not properly raised, and the record supported the court’s distributive orders.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the September 23, 2011 order relied on unsupported findings	Husband contends the court made findings not supported by the record.	Wife asserts the court relied on admitted or properly incorporated evidence.	No abuse; findings supported by the record.
Whether Exhibit 1 was properly admitted/used as record evidence	Exhibit 1 was not formally admitted and Husband never consented to its use.	Exhibit 1 was treated as record evidence and referenced by prior pleadings.	Waived objection; exhibit usage permissible in context.
Whether trial aids were properly used to resolve unresolved values	Trial aids introduced undisputed facts; they should not be used to substitute evidence.	Trial aids aided resolution and were consented to by both parties; they became part of the record.	Waived objection; trial aids properly utilized under court discretion.

Nagle v. Nagle, 799 A.2d 812 (Pa. Super. 2002) (abuse-of-discretion review; findings binding if credible evidence)
Summers v. Summers, 35 A.3d 786 (Pa. Super. 2012) (waiver when not raised below; appellate review limited)
White v. Owens-Corning Fiberglas, Corp., 447 Pa. Super. 5 (Pa. Super. 1995) (brief noncompliance may not bar review when not prejudicial)