Cameron Allen v. Lisa Allen

Summary

The Supreme Court of Wyoming affirmed a district court’s division of marital property in the divorce of Cameron and Lisa Allen. The court held that, because neither party requested special findings under W.R.C.P. 52(a)(1)(A), the judgment was presumed to include findings supporting the valuations and distribution. The court concluded that the evidence supported the valuation of the marital home and Lisa Allen’s pension accounts, and that the $850,000 equalization payment did not constitute an abuse of discretion or shock the conscience.

Holdings

1. When neither party requests special findings under W.R.C.P. 52(a)(1)(A), the district court is not required to make additional written findings concerning the valuation of particular marital assets; the judgment is presumed to include every finding necessary to support the property distribution.
2. Assuming the district court valued the marital home at $1,541,000 based on the 2025 appraisal, the evidence reasonably supported that valuation and the district court did not abuse its discretion.
3. Assuming the district court accepted Wife's testimony concerning the value of her pension accounts rather than Husband's expert's present-value calculation, that choice was supported by the evidence and was not an abuse of discretion.
4. The district court did not abuse its discretion under Wyo. Stat. Ann. § 20-2-114(a). The statute requires a just and equitable distribution, not an equal division, and the overall distribution, including the $850,000 equalization payment, did not shock the conscience.

Questions Presented

1. Whether the district court abused its discretion under Wyo. Stat. Ann. § 20-2-114(a) by valuing the marital home and Wife's pension accounts in a manner allegedly unsupported by the evidence.
2. Whether the district court abused its discretion by ordering an $850,000 equalization payment and thereby making an inequitable division of the marital estate.
3. Whether the district court was required to make written or special findings concerning the valuation of the marital home and Wife's pension accounts when neither party requested special findings under W.R.C.P. 52(a)(1)(A).

Disposition

affirmed