Tina Mitchell v. Craig Mitchell, 284 A.3d 89

Tina and Craig Mitchell married in 2009; Tina filed for divorce in December 2020 and the final hearing occurred December 14, 2021.
Pretrial and updated financial statements did not list a 2006 Ford Mustang or a 2013 Honda Rancher; Craig listed a 1968 Ford Mustang as his nonmarital property with title in his name.
Trial testimony described a joint “car flipping” business (2018–2019) but provided no competent evidence about when or how the 1968 Mustang or a 2013 Rancher were acquired; Tina offered no evidence about the 1968 Mustang.
After trial, Tina submitted a proposed judgment awarding her a 1968 Mustang (alleged gift) and a 2013 Honda Rancher; Craig asked the court to award him the 1968 Mustang.
The district court awarded Tina the 1968 Mustang as her nonmarital property and also awarded her a 2013 Honda Rancher. The Supreme Judicial Court vacated the judgment and remanded, holding the findings lacked competent evidentiary support.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the 1968 Ford Mustang is Tina's nonmarital property (gift)	Tina: the Mustang was a gift to her during marriage and should be set aside to her	Craig: title and possession show the Mustang is his nonmarital property and he asked the court to award it to him	Court: vacated classification—no competent evidence about acquisition; finding unsupported; remand for further proceedings
Whether awarding a 2013 Honda Rancher to Tina was proper	Tina: Rancher ownership was discovered at hearing and award justified by Craig hiding assets	Craig: no Rancher was listed in financials, no evidence at trial, parties did not own it at hearing	Court: vacated award—no record evidence the parties owned a 2013 Rancher at time of trial; remand

In re Child of Carl D., 207 A.3d 1202 (Me. 2019) (standard of review for trial-court factual findings)
Violette v. Violette, 120 A.3d 667 (Me. 2015) (property-division framework: classify nonmarital vs marital then divide)
Miliano v. Miliano, 50 A.3d 534 (Me. 2012) (compare acquisition date to marriage date to classify property)
Ayotte v. Ayotte, 966 A.2d 883 (Me. 2009) (burden of proof and resolving issues against party with burden when evidence is inadequate)
Ehret v. Ehret, 135 A.3d 101 (Me. 2016) (vacating factual findings unsupported by competent record evidence)
Colucci v. Colucci, 234 A.3d 1226 (Me. 2020) (trial court may reopen record on remand)
Warner v. Warner, 807 A.2d 607 (Me. 2002) (court may consider omitted property when parties later introduce evidence)
Mooar v. Greenleaf, 179 A.3d 307 (Me. 2018) (trial court may reevaluate property distribution on remand)