The Delaware Supreme Court reversed a Family Court decision that awarded more than 70% of marital home sale proceeds to one spouse, establishing new precedent for property division in Delaware divorce cases involving domestic abuse allegations. The court issued its ruling Feb. 11, 2026, in *Parks v. Carver*, limiting how much of marital property proceeds one party can receive in post-divorce proceedings.
The case stems from a brief marriage between Jared Parks and Belinda Carver, who married April 14, 2017. The relationship deteriorated rapidly, culminating in domestic abuse allegations that shaped the subsequent legal proceedings and property division dispute.
On Sept. 14, 2023, Carver filed a petition for protection from abuse against Parks, alleging various acts of domestic violence. The petition led to significant legal consequences when a Family Court Commissioner found Oct. 6, 2023, that Parks had abused Carver by showing her a paintball gun she believed was real and forcing her to sign a quit-claim deed to their marital residence.
The same day the protection order was entered, Parks filed for divorce but notably did not request the court retain jurisdiction over ancillary financial matters. He did seek custody of the couple's minor child. The divorce decree was finalized Nov. 22, 2023, in what appeared to be an uncontested proceeding.
However, the matter was far from resolved. Five days after the divorce decree, Carver filed a motion to reopen the case specifically to address property division and alimony issues that had not been resolved in the initial proceedings. Parks did not respond to this motion, allowing the Family Court to proceed with determining how marital assets should be divided.
The Family Court's subsequent ruling awarded Carver more than 70% of the proceeds from the prospective sale of the marital home. This allocation likely reflected the court's consideration of the domestic abuse findings, the forced quit-claim deed signing, and Parks' failure to participate in the reopened proceedings.
Parks appealed the Family Court's property division order to the Delaware Supreme Court, challenging both the underlying orders on ancillary matters and the denial of his motion to reopen the judgment. The case was submitted to the high court Dec. 5, 2025, with Justices Valihura, Traynor, and Legrow presiding.
In its Feb. 11, 2026 order, the Delaware Supreme Court established a clear limitation on property division in similar cases. The court held that awarding one spouse more than 70% of marital home proceeds exceeded appropriate bounds, even in cases involving domestic abuse allegations.
"We reverse the Family Court's judgment to the extent that the court awarded Ex-Wife more than 70% of the proceeds from the prospective sale of the marital home," the court wrote in its order.
The ruling represents a significant development in Delaware family law, establishing precedent for how courts should balance equitable distribution principles with considerations of domestic abuse in property division. The 70% threshold appears to represent the court's determination of the maximum allocation that maintains fairness while still accounting for misconduct affecting marital property.
The case highlights the complex intersection of domestic violence proceedings and divorce litigation. The protection from abuse order and findings of coercive behavior regarding the quit-claim deed clearly influenced the Family Court's initial property allocation. However, the Supreme Court's reversal suggests there are limits to how far such considerations can tip the scales in property division.
The timing of events in this case also illustrates common tactical considerations in divorce proceedings. Parks' decision not to request jurisdiction over financial matters in his initial divorce petition, combined with his failure to respond to Carver's motion to reopen, effectively ceded control over property division to the Family Court.
This case may influence how Delaware attorneys advise clients in similar situations involving both domestic abuse allegations and significant marital property. The ruling suggests that while courts will consider abuse allegations in property division, there are practical limits to how dramatically such findings can alter standard equitable distribution principles.
The 70% threshold established in *Parks v. Carver* provides guidance for future cases where courts must balance protection of abuse victims with fundamental fairness in property division. The ruling ensures that even in cases involving domestic violence, property division cannot become so one-sided as to effectively constitute a punitive award rather than equitable distribution.
The case remains notable for the Supreme Court's use of pseudonyms under Rule 7(d), reflecting the sensitive nature of domestic abuse allegations in family court proceedings. This practice helps protect the privacy of parties while still allowing for the development of important legal precedent.
The Delaware Supreme Court's ruling in *Parks v. Carver* will likely be cited in future family court cases involving property division where domestic abuse allegations are present, providing clear guidance on the outer limits of equitable distribution awards.