Legal Case

Katherine Dawn Brown, V. Geoffrey Bryan Thomas

Court

Court of Appeals of Washington

Decided

June 23, 2025

Jurisdiction

SA

Importance

45%

Significant

Case Summary

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON In the Matter of the Marriage of: No. 86760-1 KATHERINE DAWN THOMAS, DIVISION ONE Respondent, UNPUBLISHED OPINION and GEOFFREY BRYAN THOMAS, Appellant. COBURN, J. — Geoffrey Thomas, representing himself on appeal, challenges the order of the superior court enforcing certain terms of a previously entered and unchallenged final divorce decree. Thomas asserts that the superior court’s determination of the value and division of certain disputed household fixtures and large appliances modified the property division set forth in the decree. We disagree. Thomas also asserts that the court had no basis to award Katherine Brown 1 attorney fees and that the amount awarded was not reasonable. Although the superior court did not err in determining that Thomas was intransigent and awarding attorney fees, the superior court, based on the record before us, did not address Thomas’s objections to the reasonableness of 1 For clarity, we refer to the Respondent as Brown, her last name at the time of this decision’s publication. No. 86760-1/2 the attorney fee award and failed to enter any findings supporting the fee award other than a general conclusory finding that the fees are reasonable. Accordingly, we affirm in part, reverse in part and remand for the trial court to adequately address Thomas’ objections to the reasonableness of Brown’s requested attorney fees and costs. 2 FACTS The matter before us involves the enforcement of a dissolution decree entered following a bench trial in 2023. That decree was not appealed. Following a bench trial, the court awarded Brown sole ownership of her pre-marital property in Woodinville as her separate property, which included a residence thereon, less a real property award of $85,904 identified as “sweat equity” comprised of Thomas’s “separate pre-marital contribution to the Woodinville home.” The decree also awarded to Brown personal property described as “all possessions currently in her possession” and awarded to Thomas personal property described as “all possessions currently in his possession.” 3 And in its final paragraph, the decree ordered Thomas to vacate the Woodinville property within 60 days. 4 2 Thomas raises other challenges on appeal. None merit appellate relief as discussed below. 3 The decree also awarded each personal property as listed in “Exhibit A&L” as their separate property. This exhibit does not specifically list any of the disputed items in this matter as “separate property.” 4 Later, when Brown moved to enforce the decree, Brown’s counsel in discussing past events, referenced that “[Thomas] unilaterally moved into the separate property home of [Brown] during the divorce,” and that the superior court had previously ordered Thomas to move out the Woodinville home and granted Brown an award of attorney fees for that proceeding. Although we do not have the transcript from the dissolution trial or a subsequent proceeding that generated an award of attorney fees different than the one -2- No. 86760-1/3 Thomas later vacated the Woodinville residence. In so doing, however, he removed—and did not replace—several of the residence’s fixtures and several of its major appliances, including the kitchen’s refrigerator and the washer and dryer. Brown later filed a motion for hearing for contempt or, in the alternative, enforcement of the property division set forth in the decree, requesting the replacement value of those appliances and fixtures removed by Thomas. These items and their values, as described in her motion and as supported by accompanying exhibits, included the following: • The refrigerator – Exhibit C, Receipt; Exhibit D, Photo of it missing. • The washer and dryer – Exhibit E, Receipt; Exhibit F, Photo of them missing. A utility sink and cabinet was also removed. • Miniature fridge/fridge drawers (there is nothing else that could reasonably occupy this odd space) – Exhibit G, Receipt; Exhibit H, Photo of it missing. • Downstairs light fixture – Exhibit I, Photo of missing light fixture. • Two built-in bookshelves (there is not even installed carpet where they used to be) – Exhibit J, Receipt; Exhibit K, Photo of them missing. • The mirrors in the master bathroom – Exhibit L, Receipt; Exhibit M, Photo of them missing. • An entire sink/vanity from the downstairs bathroom (this sam

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Case Details

Case Details

Legal case information

Status

Decided

Date Decided

June 23, 2025

Jurisdiction

SA

Court Type

federal

Legal Significance

Case importance metrics

Importance Score
Significant
Score45%
Citations
0

Metadata

Additional information

AddedJun 23, 2025
UpdatedJun 23, 2025

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Court Proceedings

Date FiledJune 23, 2025
Date DecidedJune 23, 2025

Document Details

Times Cited
0
Importance Score
0.4

Legal Classification

JurisdictionSA
Court Type
federal