In the Matter of Tammy Rokowski and Shane Rokowski, 121 A.3d 284

Married in 1990; petitioner Tammy Rokowski and respondent Shane Rokowski have two adult sons.
The couple’s significant assets include a marital home in Connecticut and the respondent’s businesses; the home was owned via grandparents’ life estate at marriage.
The parties moved to New Hampshire in 2006 to establish a fireworks business; the respondent remained in Connecticut initially.
Tammy filed for divorce and a domestic violence order in 2011; the order was temporary and dismissed with the final decree.
A two-day final hearing occurred in 2013, resulting in a divorce based on irreconcilable differences; the court issued a 2014 decree with property, alimony, and expense provisions.
The trial court valued the marital home at $150,000, awarded it to the respondent, and ordered Tammy to receive $75,000 secured by a mortgage; the respondent’s businesses were awarded to him; Tammy’s alimony was set at $750 per month.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred by using internet data to value the home	Rokowski contends Zillow data is inadmissible outside-record information.	Rokowski argues court’s internet data was appropriate for valuation given lack of formal appraisals.	Court erred; vacate property distribution and remand.
Whether the property distribution and alimony were properly determined	Rokowski maintains the erroneous valuation affected asset division and alimony.	Rokowski contends distribution and alimony were based on the record before the court.	Because distribution vacated, alimony order also vacated; remand for correct valuation.
Whether the trial court properly allocated expenses incurred during the divorce	Tammy asserts trial court miscalculated or improperly assigned expenses.	Shane asserts the trial record supports the allocations.	We affirm the challenged expense allocations due to lack of complete record on appeal.
Whether constitutional arguments were preserved for review			Court declined to address constitutional claims; deemed waived for lack of preservation.

Spenard & Spenard, 167 N.H. 1 (2014) (trial court permissibly exercises discretion; standard of review)
Morse v. Allen, 45 N.H. 571 (1864) (trial court may not rely on outside evidence beyond the record)
In re Schrag, 464 B.R. 909 (Bankr. D. Or. 2011) (court may not rely on unverified internet sources; limits on judicial notice)
Klemow v. Time Incorporated, 352 A.2d 12 (Pa. 1975) (court may not introduce its own evidence; evidentiary limits)
Rutanhira v. Rutanhira, 35 A.3d 143 (Vt. 2011) (reversible error when relying on post-evidence internet data not meeting notice standards)
Tribbitt v. Tribbitt, 963 A.2d 1128 (Del. 2008) (trial court’s outside-of-record job search unsupported by record)
State v. Ploof, 162 N.H. 609 (2011) (necessity of trustworthy evidence; evidentiary standards)
In re Estate of King, 149 N.H. 226 (2003) (preservation and waiver principles on appeal)