Susan G. Colucci v. Stephen Colucci, 234 A.3d 1226

Susan and Stephen Colucci married in May 2015; Susan filed for divorce in October 2017.
In her court financial statement Susan listed two dogs and indicated one dog, Louise, was acquired in 2010 (pre‑marriage).
At trial the parties presented no evidence identifying which spouse actually acquired Louise in 2010.
The District Court granted the divorce and ordered both dogs set aside to Susan as her exclusive property, without making express factual findings about the dogs.
Stephen moved under M.R. Civ. P. 52 asking the court to find Louise is his nonmarital property; the court denied the motion and Stephen appealed.
The Supreme Judicial Court held that Louise was nonmarital because she was acquired before the marriage, but vacated and remanded because the record lacked evidence identifying which spouse had acquired Louise, so the court could not properly set the dog aside to the correct owner.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Classification and ownership of Louise (the dog)	Louise should be awarded to Susan as her property	Louise is Stephen's nonmarital property because it was acquired before the marriage	Louise is nonmarital (acquired pre‑marriage), but remand required because record did not show which spouse acquired her, so court must determine ownership or reopen record
Ambiguity of judgment re: corporation profits payment	(Susan) Judgment is clear and enforceable	(Stephen) Ambiguous whether profits are before or after his director salary	Court found no ambiguity after post‑judgment clarification that Stephen may account for a reasonable salary when calculating the amount due

Miliano v. Miliano, 50 A.3d 534 (Me. 2012) (property acquired before marriage is nonmarital; court must set aside nonmarital property to its owner)
McLean v. Robertson, 225 A.3d 410 (Me. 2020) (when a party files a Rule 52 motion the judgment must be supported by factual findings based on record evidence; court may need to reopen the record)