The South Carolina Court of Appeals has affirmed a divorce decree involving Susan Koutsogiannis and George Koutsogiannis. The court ruled on October 21, 2026, in case number 2023-000996, addressing key issues related to the valuation of marital property and the conduct of both parties during the divorce proceedings. This ruling is significant as it clarifies the responsibilities of parties in divorce cases regarding property appraisals and mediation.
Susan Koutsogiannis, the respondent, filed for divorce from her husband, George Koutsogiannis, on September 24, 2021. The couple was embroiled in a dispute over the equitable division of their marital estate. George Koutsogiannis, the appellant, counterclaimed for divorce on the grounds of adultery, seeking a division of the marital property and attorney fees for defending against his wife's claims.
The case took a turn when, on November 1, 2022, the family court dismissed the case without prejudice due to the parties' failure to request a final hearing within the required 365 days. However, after Susan's attorney informed the court of George's lack of cooperation in mediation and appraisals, the court reinstated the case on January 12, 2023. The court also set a final hearing for April 5, 2023, and required George to cooperate with appraisals and attend mediation.
George did not attend the scheduled mediation, leading to further complications during the trial. At the trial, Susan presented valuations of the marital property, which George's attorney objected to, arguing they were based on recent values rather than the values at the time of filing for divorce. The family court had previously issued a pretrial order stating that if George did not cooperate, he would be barred from introducing evidence regarding the property’s valuation. The court upheld this order during the trial, which ultimately led to George being unable to present his valuation evidence.
The court ruled, "If [Husband] continues to refuse to cooperate with appraising real properties and/or refuses to attend [m]ediation in this matter, [Husband] shall be precluded from introducing any evidence regarding the value of marital property." This ruling was part of the court's decision to affirm the divorce decree, which also granted George a divorce on the grounds of adultery and required him to pay $5,000 for appraisal costs.
In its analysis, the court addressed several issues raised by George on appeal. He argued that the family court lacked subject matter jurisdiction when it issued the pretrial order and that the court erred in its valuation of the marital property. However, the court found that it had subject matter jurisdiction over divorce and equitable division cases, affirming that the family court could adjudicate these matters.
Furthermore, the court noted that George's arguments regarding the pretrial order were not preserved for appellate review because he did not raise them during the trial. The court stated that, "In order to preserve an issue for appellate review, a party must both raise that issue to the trial court and obtain a ruling." This meant that George's objections to the pretrial order were not valid for the appeal.
The court also addressed George's claims regarding the valuation of marital property and the denial of his request for attorney fees. The court found that George's arguments were largely abandoned due to a lack of legal authority in his brief. The court concluded, "An issue is deemed abandoned if the argument in the brief is only conclusory."
The ruling has implications for future divorce cases in South Carolina, particularly in how parties must engage in the appraisal and mediation processes. It underscores the importance of cooperation during divorce proceedings and the consequences of failing to adhere to court orders.
Looking ahead, George Koutsogiannis may have limited options for further legal action. The court's ruling is final unless he seeks further review, which could be challenging given the court's clear findings and the lack of preserved issues. There are no related cases pending that were mentioned in the court filing.
This case serves as a reminder of the complexities involved in divorce proceedings and the critical importance of following court orders regarding mediation and property valuation.