Missouri Court of Appeals, Eastern District / Apr 16, 2024
Angela M. Karstens, Respondent, vs. Kenneth L. Evans, Appellant.
Angela Karstens filed a partition action against Kenneth Evans for the sale of their jointly owned home. The trial court awarded Karstens ordinary and substantial attorney's fees, to be paid entirely by Evans, and allocated the sale proceeds. Evans appealed the attorney's fees award. The appellate court reversed and remanded, finding the trial court erred by combining the ordinary and substantial attorney's fees without specifying amounts, and by awarding substantial attorney's fees because Evans' conduct did not meet the threshold for such an award.