Jones v. Jones, 2014 Ark. 96

Charles and Myra Jones married in 1992 and divorced after Myra filed for dissolution in 2011; no children. Dispute centered on division of property and marital debt.
Myra owned a home on Kyler Road before the marriage; Charles owned undeveloped Chinn Springs Road land before marriage but deeded it to them as husband and wife in 1997.
During the marriage marital funds (income, insurance proceeds) were used to pay loans secured by the Kyler Road home and to make improvements; debt on that home grew from about $16,000 at marriage to ~$59,000 at divorce.
The parties owned three vehicles (a Mercedes given to Myra in 2009 and two trucks used by Charles in his heating-and-air business), several life-insurance policies on Charles, an unprofitable antique shop in Myra’s name, and accrued significant credit‑card and loan debt.
Circuit court ruled Kyler Road home was Myra’s separate property; awarded Myra the Mercedes, Charles the trucks and miniature horses; ordered sale of Chinn Springs land and marital items to pay debts; divided cash values of life policies equally. Court of appeals affirmed; Arkansas Supreme Court granted review and affirmed the circuit court.

Issue	Plaintiff's Argument (Charles)	Defendant's Argument (Myra)	Held
Interest in Kyler Road home	Marital funds paid debt and made improvements; he is entitled to an interest or benefit.	Home was Myra’s separate premarital property; no proof improvements increased value or equity.	No error: non‑owning spouse must show marital contributions and resulting increase in value/equity; Charles failed to prove increase.
Division of vehicles	Awarding Myra the Mercedes (≈$22k) and Charles the two trucks (≈$13k) was unequal.	Court can allocate assets equitably overall; trucks are business assets Charles needs.	No error: equitable division need not be mathematically equal; court’s overall division acceptable.
Life‑insurance policies	Court erred by equally dividing cash values; policies were gifts and some in Myra’s name.	Policies existed, premiums paid with marital funds; values not fully developed in record.	No error: appellant bears burden to show trial court erred; record lacked values to demonstrate inequity.
Constructive trust for Chinn Springs land	Deed was given based on Myra’s promise to convey interest in Kyler Road home; confidential relation warrants constructive trust.	Myra denied such promise; deed was to protect loans.	No error: testimony conflicted; trial court credited Myra; constructive trust not imposed absent clear and convincing proof of fraud or confidential abuse.

Box v. Box, 312 Ark. 550, 851 S.W.2d 437 (recognizing non‑owning spouse may obtain benefit where marital funds pay debt on nonmarital property)
Bagwell v. Bagwell, 282 Ark. 403, 668 S.W.2d 949 (trial court may award benefit when marital funds pay off debts on owning spouse’s nonmarital property)
Williford v. Williford, 280 Ark. 71, 655 S.W.2d 398 (non‑owning spouse entitled to benefit when marital funds improve nonmarital property)
Farrell v. Farrell, 365 Ark. 465, 231 S.W.3d 619 (expenditure of marital funds does not automatically convert nonmarital property into marital property; burden to prove increase in value/equity)
Brown v. Brown, 373 Ark. 333, 284 S.W.3d 17 (standard of review for property division: affirm unless clearly erroneous)
Conlee v. Conlee, 370 Ark. 89, 257 S.W.3d 543 (definition of clearly erroneous on review)
Pinkston v. Pinkston, 278 Ark. 233, 644 S.W.2d 930 (trial court has discretion in exact apportionment of marital property)
Young v. Young, 288 Ark. 33, 701 S.W.2d 369 (appellant must bring a record sufficient to demonstrate trial court error)
Robertson v. Robertson, 229 Ark. 649, 317 S.W.2d 272 (elements for imposing a constructive trust based on an oral promise)
Walker v. Biddle, 225 Ark. 654, 284 S.W.2d 840 (constructive trust requires clear and convincing proof of fraudulent promise or confidential relationship)