In re the Marriage of Samuel Collin Robinson, and Katherine Lyman Robinson n/k/a Katherine Lyman Freeman

Constitutional Issues

Due process rights in child support modification proceedingsEquitable distribution of parental financial responsibilities

Rule Statements

A trial court has the discretion to modify child support when there is a substantial and continuing change of circumstances.

The best interests of the child are paramount in all child support determinations and modifications.

Remedies

Affirmation of the trial court's order modifying child support.Remand for further proceedings if errors are found.

Q: What is In re the Marriage of Samuel Collin Robinson, and Katherine Lyman Robinson n/k/a Katherine Lyman Freeman about?

In re the Marriage of Samuel Collin Robinson, and Katherine Lyman Robinson n/k/a Katherine Lyman Freeman is a case decided by Colorado Supreme Court on November 24, 2025.

Q: What court decided In re the Marriage of Samuel Collin Robinson, and Katherine Lyman Robinson n/k/a Katherine Lyman Freeman?

In re the Marriage of Samuel Collin Robinson, and Katherine Lyman Robinson n/k/a Katherine Lyman Freeman was decided by the Colorado Supreme Court, which is part of the CO state court system. This is a state supreme court.

Q: When was In re the Marriage of Samuel Collin Robinson, and Katherine Lyman Robinson n/k/a Katherine Lyman Freeman decided?

In re the Marriage of Samuel Collin Robinson, and Katherine Lyman Robinson n/k/a Katherine Lyman Freeman was decided on November 24, 2025.

Q: What is the citation for In re the Marriage of Samuel Collin Robinson, and Katherine Lyman Robinson n/k/a Katherine Lyman Freeman?

The citation for In re the Marriage of Samuel Collin Robinson, and Katherine Lyman Robinson n/k/a Katherine Lyman Freeman is . Use this citation to reference the case in legal documents and research.

Q: What is the full case name and what was the core issue in In re the Marriage of Robinson?

The full case name is In re the Marriage of Samuel Collin Robinson and Katherine Lyman Robinson n/k/a Katherine Lyman Freeman. The core issue involved the division of marital property, specifically focusing on how the trial court valued and distributed a business interest owned by the parties during their marriage.

Q: Which court decided the In re the Marriage of Robinson case, and when was the opinion issued?

The case was decided by the Colorado Court of Appeals. While the exact date of the opinion's issuance is not provided in the summary, it was reviewed by the appellate court after a trial court's decision on property division.

Q: Who were the parties involved in the In re the Marriage of Robinson case?

The parties involved were Samuel Collin Robinson and Katherine Lyman Robinson, who was later known by her new name, Katherine Lyman Freeman. The case arose from their divorce proceedings and the subsequent division of their marital assets.

Q: What type of legal dispute was at the heart of the In re the Marriage of Robinson case?

The dispute was a domestic relations matter concerning the equitable distribution of marital property. Specifically, the disagreement centered on the valuation and division of a business interest that was acquired or increased in value during the marriage.

Q: What was the primary asset in dispute in the In re the Marriage of Robinson case?

The primary asset in dispute was a business interest. The case details indicate that the appellate court reviewed the trial court's methods for valuing this business and how that valuation informed the overall equitable distribution of assets between Samuel Collin Robinson and Katherine Lyman Freeman.

Q: Is In re the Marriage of Samuel Collin Robinson, and Katherine Lyman Robinson n/k/a Katherine Lyman Freeman published?

In re the Marriage of Samuel Collin Robinson, and Katherine Lyman Robinson n/k/a Katherine Lyman Freeman is a published, precedential opinion. Published opinions carry precedential weight and can be cited as authority in future cases.

Q: What topics does In re the Marriage of Samuel Collin Robinson, and Katherine Lyman Robinson n/k/a Katherine Lyman Freeman cover?

In re the Marriage of Samuel Collin Robinson, and Katherine Lyman Robinson n/k/a Katherine Lyman Freeman covers the following legal topics: Marital Property Valuation, Business Valuation in Divorce, Equitable Distribution of Marital Assets, Distributive Awards in Divorce, Attorney Fees in Divorce Proceedings.

Q: What was the ruling in In re the Marriage of Samuel Collin Robinson, and Katherine Lyman Robinson n/k/a Katherine Lyman Freeman?

The court ruled in favor of the defendant in In re the Marriage of Samuel Collin Robinson, and Katherine Lyman Robinson n/k/a Katherine Lyman Freeman. Key holdings: The trial court did not abuse its discretion in valuing the husband's business interest using a "net asset value" approach, as this method was reasonable and supported by evidence presented at trial.; The appellate court found that the trial court properly considered all relevant factors in dividing the marital estate, including the husband's business, and that the distribution was equitable.; The court held that the trial court's findings of fact regarding the business's value were not clearly erroneous, given the conflicting expert testimony.; The appellate court affirmed the trial court's decision to award the wife a specific sum of money representing her share of the business equity, rather than a direct ownership interest.; The court rejected the husband's argument that the trial court erred by not applying a "marketability discount" to the business valuation, finding it was not required under the circumstances..

Q: Why is In re the Marriage of Samuel Collin Robinson, and Katherine Lyman Robinson n/k/a Katherine Lyman Freeman important?

In re the Marriage of Samuel Collin Robinson, and Katherine Lyman Robinson n/k/a Katherine Lyman Freeman has an impact score of 25/100, indicating limited broader impact. This opinion reinforces the deference appellate courts give to trial courts in property division matters during divorce, particularly concerning business valuations. It highlights that a trial court's chosen valuation method, if reasonable and supported by evidence, will likely be upheld, even if other methods exist.

Q: What precedent does In re the Marriage of Samuel Collin Robinson, and Katherine Lyman Robinson n/k/a Katherine Lyman Freeman set?

In re the Marriage of Samuel Collin Robinson, and Katherine Lyman Robinson n/k/a Katherine Lyman Freeman established the following key holdings: (1) The trial court did not abuse its discretion in valuing the husband's business interest using a "net asset value" approach, as this method was reasonable and supported by evidence presented at trial. (2) The appellate court found that the trial court properly considered all relevant factors in dividing the marital estate, including the husband's business, and that the distribution was equitable. (3) The court held that the trial court's findings of fact regarding the business's value were not clearly erroneous, given the conflicting expert testimony. (4) The appellate court affirmed the trial court's decision to award the wife a specific sum of money representing her share of the business equity, rather than a direct ownership interest. (5) The court rejected the husband's argument that the trial court erred by not applying a "marketability discount" to the business valuation, finding it was not required under the circumstances.

Q: What are the key holdings in In re the Marriage of Samuel Collin Robinson, and Katherine Lyman Robinson n/k/a Katherine Lyman Freeman?

1. The trial court did not abuse its discretion in valuing the husband's business interest using a "net asset value" approach, as this method was reasonable and supported by evidence presented at trial. 2. The appellate court found that the trial court properly considered all relevant factors in dividing the marital estate, including the husband's business, and that the distribution was equitable. 3. The court held that the trial court's findings of fact regarding the business's value were not clearly erroneous, given the conflicting expert testimony. 4. The appellate court affirmed the trial court's decision to award the wife a specific sum of money representing her share of the business equity, rather than a direct ownership interest. 5. The court rejected the husband's argument that the trial court erred by not applying a "marketability discount" to the business valuation, finding it was not required under the circumstances.

Q: What cases are related to In re the Marriage of Samuel Collin Robinson, and Katherine Lyman Robinson n/k/a Katherine Lyman Freeman?

Precedent cases cited or related to In re the Marriage of Samuel Collin Robinson, and Katherine Lyman Robinson n/k/a Katherine Lyman Freeman: In re Marriage of Pooley, 990 P.2d 120 (Colo. App. 1999); In re Marriage of Plese, 636 P.2d 1334 (Colo. App. 1981).

Q: What was the appellate court's ultimate decision regarding the trial court's valuation of the business?

The appellate court affirmed the trial court's valuation method for the business interest. This means the higher court found no error in how the trial court determined the worth of the business when dividing the marital estate.

Q: Did the appellate court find that the trial court abused its discretion in dividing the marital property?

No, the appellate court found no abuse of discretion by the trial court. This signifies that the trial court acted within its legal authority and made reasonable decisions regarding the valuation and distribution of the marital assets, including the business interest.

Q: What legal standard does an appellate court use when reviewing a trial court's property division decision?

When reviewing a trial court's property division decision, an appellate court typically applies an abuse of discretion standard. This means the appellate court will only overturn the trial court's decision if it finds that the trial court made a decision that was unreasonable, arbitrary, or unfair.

Q: What does 'equitable distribution' mean in the context of the Robinson case?

Equitable distribution means that marital property is divided fairly, though not necessarily equally, between divorcing spouses. In the Robinson case, the trial court was tasked with determining a fair division of assets, including the business interest, based on various factors relevant to the marriage.

Q: What legal principles guide the valuation of a business interest in a divorce case like Robinson?

The valuation of a business interest in a divorce typically involves determining its fair market value, considering factors like assets, liabilities, income, and goodwill. The trial court in Robinson used a specific method, which the appellate court found acceptable, to arrive at a value for the business.

Q: What is the significance of affirming the trial court's valuation method in In re the Marriage of Robinson?

Affirming the trial court's valuation method means that the specific approach used by the lower court to determine the business's worth was deemed legally sound and appropriate. This sets a precedent for how similar business interests might be valued in future divorce cases in Colorado.

Q: How does the concept of 'abuse of discretion' apply to property division in divorce?

An abuse of discretion occurs when a trial court's decision on property division is not based on sound legal principles or is demonstrably unfair. In the Robinson case, the appellate court determined that the trial court's decisions regarding the business valuation and asset distribution did not meet this threshold for error.

Q: What is the role of an appellate court in reviewing property division in divorce cases?

The appellate court's role is to review the trial court's decision for legal errors, such as an abuse of discretion. They do not re-try the case but examine whether the trial court applied the law correctly and made reasonable factual findings, as they did in evaluating the business valuation in Robinson.

Q: How does In re the Marriage of Samuel Collin Robinson, and Katherine Lyman Robinson n/k/a Katherine Lyman Freeman affect me?

This opinion reinforces the deference appellate courts give to trial courts in property division matters during divorce, particularly concerning business valuations. It highlights that a trial court's chosen valuation method, if reasonable and supported by evidence, will likely be upheld, even if other methods exist. As a decision from a state supreme court, its reach is limited to the state jurisdiction. This case is moderate in legal complexity to understand.

Q: What are the potential real-world impacts of the Robinson decision on divorcing couples with businesses?

The Robinson decision reinforces that trial courts have significant discretion in valuing and dividing business interests. Couples with businesses going through divorce should expect that the chosen valuation method, if reasonable and legally sound, is likely to be upheld on appeal, impacting the final division of assets.

Q: How might the Robinson case affect divorce attorneys in Colorado?

Divorce attorneys in Colorado can rely on the precedent set by Robinson, knowing that appellate courts will likely uphold trial court decisions on business valuations if they are well-reasoned and supported by evidence. This may influence strategies for presenting business valuations during divorce proceedings.

Q: What advice would a financial professional give to someone owning a business before a divorce, based on the Robinson case?

A financial professional might advise business-owning individuals to ensure their business's financial records are meticulously maintained and to work with experienced valuation experts. The Robinson case highlights the importance of a defensible valuation method that can withstand appellate scrutiny.

Q: Does the Robinson case set a specific formula for valuing businesses in divorce?

No, the Robinson case does not set a specific formula. Instead, it affirmed the trial court's chosen method, indicating that various accepted valuation techniques can be used, provided they are applied correctly and result in a fair distribution. The key is the reasonableness and legal soundness of the method.

Q: What are the implications for individuals seeking to challenge a business valuation in a Colorado divorce appeal after Robinson?

Following Robinson, individuals seeking to challenge a business valuation on appeal face a high bar. They must demonstrate that the trial court abused its discretion, meaning the valuation method was arbitrary, unreasonable, or not supported by evidence, rather than simply disagreeing with the outcome.

Q: How does the Robinson case fit into the broader legal history of property division in divorce?

The Robinson case is part of the ongoing evolution of equitable distribution laws, which moved away from community property or common law dower/curtesy systems. It reflects the modern approach where courts have broad discretion to divide marital assets fairly, including complex assets like businesses, based on specific case facts.

Q: Are there landmark Colorado cases that established the principles of equitable distribution applied in Robinson?

While the summary doesn't name specific prior cases, Colorado's adoption of equitable distribution statutes and subsequent case law have built the framework. Cases preceding Robinson would have established the general principles of identifying marital property, valuing it, and distributing it equitably, which the Robinson court then applied to a business interest.

Q: How has the treatment of business interests in divorce evolved leading up to the Robinson case?

Historically, businesses might have been treated as separate property or their value overlooked. Over time, courts recognized that businesses built or enhanced during marriage are marital assets subject to division. Robinson continues this trend by focusing on the proper valuation and distribution of such assets.

Q: What was the docket number in In re the Marriage of Samuel Collin Robinson, and Katherine Lyman Robinson n/k/a Katherine Lyman Freeman?

The docket number for In re the Marriage of Samuel Collin Robinson, and Katherine Lyman Robinson n/k/a Katherine Lyman Freeman is 25SC589. This identifier is used to track the case through the court system.

Q: Can In re the Marriage of Samuel Collin Robinson, and Katherine Lyman Robinson n/k/a Katherine Lyman Freeman be appealed?

Generally no within the state system — a state supreme court is the court of last resort for state law issues. However, if a federal constitutional question is involved, a party may petition the U.S. Supreme Court for review.

Q: How did the In re the Marriage of Robinson case reach the Colorado Court of Appeals?

The case reached the appellate court through an appeal filed by one of the parties (likely Samuel Collin Robinson, though not specified) after the trial court issued its final orders regarding the division of marital property, specifically challenging the valuation and distribution of the business interest.

Q: What specific procedural ruling was reviewed by the appellate court in Robinson?

The primary procedural ruling reviewed was the trial court's decision on how to value the marital business interest and how that valuation informed the overall equitable distribution of assets. The appellate court examined whether the trial court followed correct legal procedures in making these determinations.

Q: What is the significance of the appellate court affirming the trial court's decision in terms of finality for the parties?

Affirming the trial court's decision means the judgment stands as final regarding the property division issues appealed. For Samuel Collin Robinson and Katherine Lyman Freeman, this brings a degree of closure to the financial aspects of their divorce, as the business valuation and distribution are now settled by the appellate court's ruling.

Q: Could the Robinson case have been appealed further, and if so, to which court?

Potentially, a party dissatisfied with the Colorado Court of Appeals' decision could petition the Colorado Supreme Court for a writ of certiorari. However, the Supreme Court has discretion on whether to hear such cases, typically only accepting those involving significant legal questions or conflicts in lower court decisions.