Lee v. Lee, 2012 Miss. LEXIS 36

Corey Lee filed for divorce on habitual cruelty; Jean Lee countersued on same ground.
Corey represented himself after his attorney withdrew and pursued his claim.
On trial day Corey arrived late; chancellor dismissed his complaint and granted Jean divorce, property division, custody, and child support.
Corey hired counsel post-judgment and moved to vacate and for a new trial; he challenged asset division and sought Ferguson findings.
Court of Appeals held Corey procedurally barred for not raising the issue below; we granted certiorari
Corey raised the equitable-division issue in Rule 59; chancellor failed to apply Ferguson’s guidelines and provide findings of fact and conclusions of law.
We reverse and remand to conduct a new hearing in accord with Ferguson and this opinion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was Lee's equitable-division challenge properly raised below?	Lee raised it in Rule 59 motion.	Lee procedurally barred because not raised at trial.	Lee properly raised the issue below.
Did the chancellor err by not making Ferguson-compliant findings of fact and conclusions of law?	Ferguson requires findings of fact and application of guidelines.	Chancellor referenced Ferguson but did not detail factors in the order.	Chancellor’s failure to apply Ferguson constitutes reversible error.

Ferguson v. Ferguson, 639 So.2d 921 (Miss. 1994) (mandates findings of fact and law for equitable division; guidelines must be applied and explained)
Luse v. Luse, 992 So.2d 659 (Miss. Ct. App. 2008) (default/divorce context; need for rigorous explanation of rulings in default situations)
Stinson v. Stinson, 738 So.2d 1259 (Miss. Ct. App. 1999) (requires rigorous explanation of rulings in chancery matters)
Weathersby v. Weathersby, 693 So.2d 1348 (Miss. 1997) (relevance to guidelines and judicial explanation in asset division)