The Alabama Court of Civil Appeals recently issued a ruling in the divorce case of Lacey Dawn McCutcheon v. Zachary McCutcheon, impacting how property is divided after divorce. The court found that the lower court had acted outside its authority when it amended a previous judgment regarding the couple's assets. This decision is significant for individuals navigating divorce proceedings, particularly concerning the division of property and the importance of timely court rulings.
The case began when Lacey Dawn McCutcheon filed for divorce from Zachary McCutcheon on December 14, 2023. After both parties presented their cases, the Shelby Circuit Court issued a judgment on May 13, 2025, granting the divorce and dividing their personal property. Each party was awarded the property they possessed, and they were responsible for any debts in their names. However, the court did not specifically address the couple's RV camper in its ruling.
In the months following the initial judgment, both parties filed postjudgment motions. Lacey requested that the court amend the judgment to include the camper, while Zachary sought to clarify the debts associated with the camper. The trial court issued an order on September 16, 2025, attempting to amend the May judgment, but this order came after the 90-day period allowed for ruling on postjudgment motions under Alabama law.
The wife appealed the trial court's September order, arguing that it was void because the court had lost jurisdiction to rule on the postjudgment motions after the 90-day deadline. The appeal was assigned the number CL-2025-0851, but it was dismissed on October 22, 2025. Subsequently, Lacey filed a motion on March 31, 2026, asserting that the September order was void due to the trial court's lack of jurisdiction.
The Court of Civil Appeals, led by Judge Edwards, agreed with Lacey's argument. The court emphasized that a trial court must rule on postjudgment motions within the specified time frame, or it loses the authority to do so. The court stated, "If a trial court does not rule on a post-judgment motion within 90 days, it loses jurisdiction to rule on the motion." This ruling clarified that the failure to address all jointly owned property in a divorce does not render the judgment nonfinal.
The court ultimately reversed the trial court's denial of Lacey's Rule 60(b)(4) motion, which sought to vacate the September order. The court ordered the trial court to vacate that void order and clarified that the ownership of the camper and any associated debts remained unaffected by the May judgment.
This ruling has important implications for future divorce cases in Alabama. It reinforces the necessity for trial courts to adhere to procedural timelines when handling postjudgment motions. The decision also highlights the importance of clearly addressing all marital property in divorce judgments to avoid ambiguity and potential disputes.
The court's ruling may set a precedent for similar cases, emphasizing that parties in divorce proceedings should ensure all assets are properly accounted for in final judgments. This case serves as a reminder for individuals going through divorce to be vigilant about their rights and the legal processes involved.
Looking ahead, it is unclear whether Zachary McCutcheon will seek further appeal options following this ruling. The court's decision to reverse and remand the case indicates that the matter will return to the trial court for further action, specifically to address the void September order. Details were not available in the court filing regarding any related cases that may be pending.