Vanessa Lea Williams a/k/a Vannessa Lea Williams v. Eric Allen Williams

Summary

The Florida Fourth District Court of Appeal reviewed an amended final judgment of dissolution of marriage involving classification and equitable distribution of the marital home, allocation of debts, valuation of marital furnishings, child-support arrearages, and reservations of jurisdiction. The court affirmed classification of the home as marital property but reversed and remanded for correction of the debt allocation, clarification of the furnishings valuation, removal of child-support arrearages, and elimination of improper blanket reservations of jurisdiction.

Holdings

1. A residence conveyed to the wife during the intact marriage remained a marital asset when the prior dissolution action in which the conveyance occurred was voluntarily dismissed without a final adjudication, and the wife did not establish a valid written agreement excluding the residence from the marital estate.
2. The wife's argument that the marital settlement agreement constituted an executed provision binding after reconciliation was not preserved because she did not seek enforcement in the pleadings or pretrial statement and expressly waived enforcement at trial.
3. The circuit court erred by equitably distributing the parties' credit-card and other debts after the parties stipulated that each would retain debts in their own name and the court orally pronounced that it was not equitably dividing debts.
4. The amended final judgment was internally inconsistent regarding the value of marital furnishings and had to be reversed and remanded for clarification and consistent equitable distribution.
5. The circuit court violated the husband's due process rights by including child-support arrearages in the amended final judgment when the issue was not pleaded, noticed for hearing, tried by consent, or raised at trial, and the parties had stipulated that no arrearages existed.
6. The circuit court erred as a matter of law by reserving jurisdiction broadly to determine additional equitable-distribution terms or modify the final judgment after property rights had been fixed.

Questions Presented

1. Whether the residence conveyed to the wife by quitclaim deed during a prior dissolution proceeding that was later voluntarily dismissed was marital or nonmarital property.
2. Whether the wife's argument that the prior marital settlement agreement excluded the residence from the marital estate was preserved for appellate review.
3. Whether the circuit court improperly distributed credit-card and other debts contrary to the parties' stipulation and oral pronouncement.
4. Whether the amended final judgment was internally inconsistent regarding the value of marital furnishings and the equalizing payment.
5. Whether the circuit court violated the husband's due process rights by sua sponte including child-support arrearages in the amended final judgment.
6. Whether the circuit court erred by including blanket reservations of jurisdiction allowing modification of fixed property rights.

Disposition

reversed_and_remanded