Paul v. Lacoste v. Laura R. Lacoste, 197 So. 3d 897

Paul and Laura Lacoste divorced after Laura obtained a judgment for habitual cruel and inhuman treatment; they have two minor children.
Chancellor awarded Laura sole legal and physical custody, $1,000/month rehabilitative alimony for 24 months, child support of $4,280/month, and an equitable division of marital assets leaving Paul with 100% of his business (Next Level Sports, LLC — NLS) and ordered Paul to pay Laura $73,000 over ten years.
Paul moved for a new trial; chancellor denied and excluded posttrial evidence (Laura’s alleged move, tax consequences of her retirement withdrawal, and changed income), ruling such matters better suited for modification.
On appeal Paul challenged custody/visitation, child support calculation, valuation of NLS and resulting property division/alimony, exclusion of posttrial evidence, and asserted cumulative error.
The appellate court affirmed custody, visitation, child support, exclusion of posttrial evidence, and rehabilitative alimony; but reversed and remanded on the valuation of NLS and equitable distribution because the chancellor’s valuation relied on a single year’s profit figure and lacked adequate proof and exclusion of goodwill.

Issue	Plaintiff's Argument (Paul)	Defendant's Argument (Laura)	Held
Custody & visitation	Chancellor abused discretion awarding Laura sole custody and reduced visitation	Laura primary caregiver; record supports best-interest findings	Affirmed — chancellor’s Albright-based findings supported by substantial evidence
Child support	Statutory guideline misapplied: no written findings, failed to account for income fluctuation and extra expenses	Chancellor made adequate written findings and considered fluctuations; additional obligations may be ordered above base support	Affirmed — findings sufficient; guideline application reasonable; extra obligations may be awarded in addition to base support
Valuation of NLS & equitable division	Valuation incorrect (used single year profit; may have included goodwill); resulted in unjust property division	Chancellor used best available evidence and parties failed to present valuation expert	Reversed and remanded — valuation unsupported; remand for adequate valuation (parties’ proof or expert; exclude goodwill); then revisit property division and nonalimony awards
Posttrial/newly discovered evidence	Chancellor erred by excluding evidence of Laura’s move, tax changes, and income decline	Evidence was not "newly discovered" or arose posttrial; better addressed in modification	Affirmed — exclusion proper under Rule 59; evidence not newly discovered and/or occurred after trial

Albright v. Albright, 437 So.2d 1003 (Miss. 1983) (factors governing child-custody determinations)
McNeil v. Hester, 753 So.2d 1057 (Miss. 2000) (standard of review for chancellor findings)
Bower v. Bower, 758 So.2d 405 (Miss. 2000) (deference to chancellor’s credibility determinations)
Ferguson v. Ferguson, 639 So.2d 921 (Miss. 1994) (factors governing equitable division of marital property)
Singley v. Singley, 846 So.2d 1004 (Miss. 2002) (business valuation methods and exclusion of goodwill in divorce valuations)
Mace v. Mace, 818 So.2d 1130 (Miss. 2002) (remand required when business valuation lacks reliable method; parties or expert may establish value)
Watson v. Watson, 882 So.2d 95 (Miss. 2004) (double-counting income in alimony and business valuation and interplay of awards)
Jenkins v. Jenkins, 67 So.3d 5 (Miss. Ct. App. 2011) (parties’ burden to present valuation evidence; chancellor not required to obtain appraisals)
Peters v. Peters, 906 So.2d 64 (Miss. Ct. App. 2005) (sufficiency of written findings when income exceeds guideline threshold)
Dunaway v. Dunaway, 749 So.2d 1112 (Miss. Ct. App. 1999) (parties’ obligation to present evidence on valuation)