Stock Split is Marital Property in Missouri Divorce

Recent Case: Split of Stock awarded to spouse is property of that spouse

Wife appeals the judgment of contempt of the Circuit Court of St. Charles County ordering her to transfer 960 shares of stock to Husband.

Decision upheld

Because the dissolution judgment awarded Husband 96 shares of Wife’s unvested MasterCard stock and the stock split ten-to-one before it vested, Husband was entitled to the resulting 960 shares. In ordering Wife to transfer to Husband 960 shares of MasterCard stock, the trial court was merely acting to enforce its prior judgment.

When stock splits, it does not grow. It just changes form. So when Wife was ordered to deliver 96 shares that split 10-1 before delivery, she was required to deliver 960 shares, and no modification of judgment was needed to give the judgment that effect. Rules provide that circuit court cannot modify a property division after 30 days past the date of Judgment, as the Judgment is then final.

PD, Appellant, vs. GB, Respondent.

Missouri Court of Appeals, Eastern District - ED102328

Filed December 8, 2015