FRETT v. FRETT (2020)

Vernon Frett (“Former Husband”) appeals the final judgment dissolving his marriage to Carolyn Frett (“Former Wife”), arguing that the trial court distributed marital assets without entering specific findings as to their values. The final judgment entered below refers to only five marital assets—the marital residence, a vacant residential lot, and three vehicles. The final judgment awarded Former Wife all of the proceeds from the sale of the marital residence and from the sale of the vacant lot without providing any valuation for those assets. Similarly the judgment awarded two of the parties’ vehicles to Former Husband and one vehicle to Former Wife, again without any asset valuation.

Section 61.075(3), Florida Statutes (2019), expressly requires trial courts to make specific written findings identifying, valuing, and distributing marital and non-marital assets and liabilities. Patino v. Patino, 122 So. 3d 961, 963 (Fla. 4th DCA 2013). The failure to include sufficient value findings in the final judgment constitutes reversible error. Id.

Because the trial court failed to make the required findings regarding equitable distribution, we reverse the final judgment. On remand, the trial court may conduct an evidentiary hearing to determine the value of the marital assets subject to equitable distribution and, based on these values, may reconsider the equitable distribution plan in its amended final judgment.

REVERSED and REMANDED with instructions.

HARRIS, J.

WALLIS and GROSSHANS, JJ., concur.