Fraud Between Spouses Under Rule 60(b)(3):
Trumble v. Trumble and the Duty of Full Asset Disclosure in Divorce Settlements

I. Introduction

The South Dakota Supreme Court’s decision in Trumble v. Trumble, 2025 S.D. 65, addresses one of the recurring problems in divorce litigation: what happens when one spouse hides or misrepresents the existence or value of a significant marital asset during settlement negotiations.

The case arises out of a 28-year marriage and a catastrophic event: the destruction by fire of the couple’s substantial waterfront property in Canada. The central dispute is not about the fire, but about insurance—specifically, the wife’s concealment of a $4 million CAD insurance policy after disclosing only a $2 million CAD policy. That concealment, and the parties’ divorce stipulation allocating the property and insurance proceeds, set the stage for a Rule 60(b)(3) motion alleging fraud.

The decision is significant for several reasons:

It expressly adopts and applies the majority federal standard for “fraud between the parties” under SDCL 15‑6‑60(b)(3), requiring:
- clear and convincing proof of fraud or misrepresentation,
- that prevented the movant from fully and fairly presenting the case, and
- a knowing and intentional misrepresentation (scienter).
It clarifies how South Dakota’s divorce cases (Jeffries, Pekelder) on “due diligence” and arm’s-length negotiations interact with the duty not to hide assets.
It reaffirms that factual findings based on documentary evidence are reviewed for clear error under SDCL 15‑6‑52(a) as amended, not de novo.
It draws attention to the procedural use of affidavits on Rule 60(b) motions and the importance of a complete factual record.

The Court ultimately affirms the finding that Wife committed fraud warranting Rule 60(b)(3) relief, but remands for further proceedings on how the marital estate, including any remaining insurance proceeds, should be equitably divided in light of changed circumstances created by a supersedeas order.

II. Factual and Procedural Background

A. The Marriage, the Fire, and the Competing Properties

Husband and Wife were married for 28 years.
They owned:
- A waterfront home on a remote Canadian island (“Canadian Property”), where Wife lived and where many of her personal belongings were located.
- A residence in Sioux Falls, where Husband lived and kept most of his belongings.
On May 31, 2023, Wife filed for divorce.
Two days later, on June 2, 2023, the Canadian Property burned to the ground.

B. Discovery and the Insurance Policies

In discovery, Husband sought information about insurance on the Canadian Property:

On October 15, 2023, Wife produced a policy from “National Insurance Company” showing:
- Coverage from February 3, 2023 to February 3, 2024.
- Replacement cost coverage.
- Limits of $2 million CAD.
- Wife as the sole named insured.
Because Husband was not a named insured, he could not independently access detailed information from the insurer and was forced to rely on Wife’s production and representations.
Over several months, Husband’s counsel:
- Served interrogatories and document requests concerning insurance.
- Repeatedly emailed Wife’s counsel requesting more comprehensive documentation.
- Received repeated assurances that all responsive documents had been provided.
Wife’s counsel affirmatively represented that:
“[Wife] has provided directly to [Husband], ALL of the documents he has requested. He has everything! The insurance company will rebuild the home at $2 million Canadian.”

Unsatisfied, Husband eventually filed a motion to compel and to place insurance proceeds in trust, but before the hearing, the parties settled.

C. The Stipulation and Divorce Decree

On March 25, 2024, the circuit court entered a divorce decree incorporating the parties’ written stipulation and agreement dividing the marital estate. Key provisions included:

Disclosure Clause (Paragraph 4):
- The parties represented they had disclosed “the existence of all property” they owned.
- If undisclosed property were later discovered, they agreed to share equally in its value or provide equivalent value in cash or other property.
Representation Clause (Paragraph 27):
- Each party acknowledged full awareness of discovery rights.
- Each confirmed that the agreement was based on a “thorough and complete disclosure” of assets and liabilities.
Property Allocation:
- Wife was awarded the Canadian Property and “any insurance proceeds” related to the fire loss.
- Husband retained the Sioux Falls property and his personal effects.
- The Canadian Property was valued by the parties at $2.8 million CAD—higher than the disclosed $2 million CAD policy limits, implying that even full policy proceeds would not fully replace the property’s value.

D. Reconstruction and the Discovery of Additional Proceeds

After the decree:

In May 2024, Wife obtained a geotechnical assessment and reconstruction cost analysis placing the rebuild cost at approximately $3.3 million CAD.
She then contracted with R Simard Contracting to rebuild the home for $4,039,821 CAD.
By October 2024—about seven months after the decree—Husband “became aware through different channels” that Wife was receiving over $4 million CAD in insurance proceeds, not just $2 million CAD.
On October 14, 2024, Husband moved for:
- Relief from judgment under SDCL 15‑6‑60(b)(3) (fraud, misrepresentation, or misconduct), and
- An order to show cause regarding Wife’s misrepresentations and possible violation of the stipulation.
On October 15, 2024, Wife forwarded an email from TD Insurance referencing a policy with $4 million CAD limits.
By October 31, 2024, Wife had replaced her prior counsel.

E. Circuit Court Rulings

A December 2, 2024 hearing was held on Husband’s Rule 60(b) motion:

The parties proceeded by affidavits only; no live testimony was taken.
They agreed to dismiss the separate show-cause motion; only Rule 60(b) was argued.
The circuit court signaled it found evidence of fraud and would enforce the stipulation’s undisclosed-property sharing clause.

On December 23, 2024, the court entered an amended order:

Finding that Wife:
- “committed fraud,”
- “failed to disclose or omitted assets,” and
- “intentionally concealed assets” by misrepresenting the insurance limits.
Ordering:
- Wife to produce all policies in effect at the time of the fire within 30 days.
- Equal division of all proceeds exceeding $2 million CAD (by reference to both SDCL 25‑4‑77 and the stipulation’s disclosure clause).
- Deposit of excess proceeds into Wife’s counsel’s trust account.
- Payment of Husband’s attorney’s fees and costs for the motion ($3,169.01).

F. Appeal and Supersedeas Undertaking

Wife appealed, and then moved for a stay and supersedeas undertaking, arguing the insurance money was contractually committed to R Simard for reconstruction and needed to be used for that purpose. Husband sought a monetary bond equal to half the undisclosed proceeds.

The circuit court:

Concluded SDCL 15‑26A‑31 applied (bond conditions not expressly covered by statute).
Granted a stay but required a non-monetary supersedeas undertaking:
- Wife must use the insurance proceeds to rebuild the house (not divert them).
- She must refrain from committing waste.
- Any excess proceeds after reconstruction must be deposited into her attorney’s trust account.

Husband sought further relief from the Supreme Court regarding bond; that motion was denied. On appeal, Wife challenged:

The finding that she committed fraud under SDCL 15‑6‑60(b)(3).
The grant of Rule 60(b) relief and the equal division of the undisclosed insurance proceeds.

III. Summary of the Supreme Court’s Opinion

The Supreme Court issued a mixed disposition: it affirmed in part and remanded.

A. Standard of Review

On Rule 60(b) rulings generally: abuse of discretion.
On factual findings (even from documentary evidence only): clear error under SDCL 15‑6‑52(a), as amended in 2000.

B. Rule 60(b)(3) Fraud Between Parties: Substantive Holding

The Court:

Explicitly distinguishes:
- Fraud upon the court (e.g., bribery, corruption of judicial process), and
- Fraud between the parties (party-to-party deception affecting the case).
For the first time, adopts the federal majority rule for fraud between the parties under Rule 60(b)(3):
- The movant must show by clear and convincing evidence that:
  - the opposing party engaged in fraud or misrepresentation,
  - that prevented the movant from fully and fairly presenting his case, and
  - the misrepresentation was knowing and intentional (scienter).

Applying that standard, the Court holds:

Wife’s concealment of a $4 million CAD policy, while repeatedly representing that a $2 million CAD policy was the only applicable coverage, constituted intentional concealment of a major marital asset.
This concealment deprived Husband of a fair opportunity to evaluate and negotiate the property division.
The circuit court’s finding of fraud is not clearly erroneous.

C. Due Diligence and Prior Divorce Precedents

Wife argued Husband failed to exercise due diligence and that the settlement was an arm’s-length transaction under Jeffries v. Jeffries, 434 N.W.2d 585 (S.D. 1989). The Supreme Court rejected this framing:

Jeffries and Pekelder hold that divorcing spouses are generally at arm’s length and bear equal responsibility to ascertain the nature and value of marital assets.
But those cases also explicitly reject any “license to hide or misrepresent” assets.
Here, Husband:
- Retained counsel.
- Issued discovery requests and pursued disclosure.
- Reasonably relied on Wife’s affirmative representations and production.
Thus, he satisfied his duty of diligence.
Wife, once discovery commenced, had a continuing obligation to fully disclose assets, which she breached.

D. Use of Affidavits and the Record

The Court notes that although affidavits are often a poor substitute for live testimony (because they are not cross-examined and may be incomplete or slanted), SDCL 15‑6‑43(e) allows motions like Rule 60(b) motions to be decided on affidavits. The Court:

Warns that courts must be cautious not to let affidavit practice “circumvent justice.”
Nonetheless, finds no procedural error here because:
- Both parties proceeded by affidavit.
- No party requested live testimony or objected to the procedure.
- The affidavits and attached materials provided clear and convincing evidence of concealment.

E. Relief Granted and Remand

On the second issue—whether the trial court properly ordered equal division of proceeds above $2 million CAD—the Court does not reach a definitive allocation.

Instead:

It recognizes the circuit court correctly granted Rule 60(b) relief based on fraud.
But it notes that, after the supersedeas order:
- Insurance proceeds were authorized to be used to rebuild the home.
- Wife was prohibited from waste.
- Any remaining proceeds must be held in trust.
As a result, it is now unclear:
- Whether any “excess” proceeds exist, and
- What the current composition and value of the parties’ assets are.
The Court characterizes the original order directing an equal split of proceeds beyond $2 million CAD as potentially moot: it may no longer present a real, live controversy susceptible to a practical judicial remedy.
Therefore, it remands for the circuit court to:
- Implement the Rule 60(b) relief in light of the current circumstances and
- Determine the appropriate equitable division of the marital estate, including any remaining insurance-related assets.

F. Appellate Attorney Fees

Both parties sought appellate attorney fees; the Court:

Awards Husband $6,253.66 in appellate attorney fees plus $37.17 in printing costs.

IV. Detailed Analysis

A. Precedents and Authorities Cited

1. Rule 60(b) Cases and Standards of Review

Estate of Mack, 2025 S.D. 7:
- Confirms Rule 60(b) decisions are reviewed for abuse of discretion.
- Defines abuse of discretion as a “fundamental error of judgment” or an “arbitrary or unreasonable” decision.
Williams Services v. Sherman, 492 N.W.2d 122 (S.D. 1992):
- Emphasizes that Rule 60(b) should be applied “liberally” in line with equitable principles to ensure justice.
Hiller v. Hiller, 2015 S.D. 58:
- Another Rule 60(b) case confirming the same standard of review in divorce contexts.

These cases collectively support the broad discretion given to trial courts to reopen judgments when fraud is demonstrated, especially where property rights and equity are involved.

2. SDCL 15‑6‑52(a) and the Standard of Review for Documentary Evidence

Prior to 2000, South Dakota had followed a practice of reviewing documentary-only findings de novo.
The Legislature amended SDCL 15‑6‑52(a) to add the language “whether based on oral or documentary evidence,” explicitly subjecting both to the clear error standard.
Post-amendment decisions such as:
- Stockwell v. Stockwell, 2010 S.D. 79,
- Gluscic v. Avera St. Luke’s, 2002 S.D. 93, and
- Faulk v. Faulk, 2002 S.D. 51
confirm that documentary-based findings are not reviewed anew.

In Trumble, Wife sought de novo review because the trial court relied solely on affidavits and documents. The Court rejected this, firmly reasserting the clear error standard. This is important doctrinally: it prevents appellate courts from reweighing documentary evidence in a way that would undermine the trial court’s role.

3. Fraud Under Rule 60(b)(3): Federal Authorities

Because South Dakota had not clearly defined “fraud between the parties” under Rule 60(b)(3), the Court turned to federal precedent:

Boddicker v. Esurance Inc., 770 F. Supp. 2d 1016 (D.S.D. 2011):
- Applies the Eighth Circuit standard that Rule 60(b)(3) relief requires clear and convincing evidence of fraud, misrepresentation, or misconduct that prevented a full and fair litigation of the case.
United States v. Metropolitan St. Louis Sewer Dist., 440 F.3d 930 (8th Cir. 2006):
- Articulates the “full and fair presentation” requirement.
Smith v. Clarke, 458 F.3d 720 (8th Cir. 2006):
- Emphasizes scienter—the misrepresentation must be knowing and intentional.
Dukes v. City of Minneapolis, 339 F. App’x 665 (8th Cir. 2009) (per curiam), and
United States v. Lee, 2020 WL 3618709 (E.D. Ark. July 2, 2020):
- Reiterate that the movant must prove intentional and deliberate fraud, not merely mistake or inadvertence.

South Dakota now formally aligns its state Rule 60(b)(3) with this federal framework in cases of fraud between parties, a substantial clarification.

4. Fraud Upon the Court vs. Fraud Between the Parties

Gifford v. Bowling, 86 S.D. 615, 200 N.W.2d 379 (1972):
- Defines “fraud upon the court” as misconduct that defiles the judicial process itself, such as:
  - bribery of a judge or juror,
  - corrupt influence exerted on the court, or
  - fraud perpetrated with the participation of an officer of the court (e.g., an attorney).
Corcoran v. McCarthy, 2010 S.D. 7:
- Reiterates the distinction between fraud upon the court and lesser frauds between parties that may be addressed through Rule 60(b)(3).

In Trumble, the Court clarifies that Wife’s conduct falls into the latter category: a serious party-to-party fraud affecting the property division, not a corruption of the judicial process itself.

5. Divorce Disclosure and Due Diligence: Jeffries and Pekelder

Jeffries v. Jeffries, 434 N.W.2d 585 (S.D. 1989):
- Holds that divorcing spouses living apart and negotiating at arm’s length are not in a special confidential relationship.
- Each spouse has responsibility to determine the nature and value of marital property (due diligence).
- But crucially: “we do not intend to grant to estranged spouses any license to hide or misrepresent the value of any marital assets, nor will any such practice be condoned.”
Pekelder v. Pekelder, 1999 S.D. 45, 591 N.W.2d 810:
- Reaffirms that Jeffries does not allow concealment or misrepresentation.
- Holds that a spouse fulfills due diligence when, as here:
  - he or she retains counsel,
  - engages in discovery, and
  - relies on the other spouse’s responses and representations.

The Supreme Court in Trumble applies Pekelder-style reasoning:

Husband did exactly what he was supposed to do—he used formal discovery, pressed for documents, and relied on what was produced and represented.
Wife’s concealment cannot be excused by saying Husband should have somehow done more, particularly when he lacked access to the insurer’s information.

6. Affidavit Evidence in Motion Practice

Estate of Eberle, 505 N.W.2d 767 (S.D. 1993); Bloom v. Bloom, 498 N.W.2d 213 (S.D. 1992); Dixon v. Dixon, 423 N.W.2d 507 (S.D. 1988):
- These decisions collectively warn that affidavits are often an inadequate and imperfect form of evidence:
  - They are not subject to cross-examination.
  - They tend to mix facts with conclusions.
  - They frequently omit key context.
- But courts have discretion under SDCL 15‑6‑43(e) to decide motions based on affidavits, so long as justice is not circumvented.

In Trumble, the Court walks a careful line:

It acknowledges the dangers of affidavit-only proof.
Yet it affirms the trial court’s choice to rely on affidavits, chiefly because:
- Both sides acquiesced to that procedure.
- The fraud was largely established by undisputed documentary evidence, and
- Wife never squarely denied the key allegations of nondisclosure.

B. The Court’s Legal Reasoning

1. Defining and Applying the Fraud Standard Under Rule 60(b)(3)

The Court’s doctrinal contribution is in formally articulating the elements of “fraud between parties” for purposes of Rule 60(b)(3):

Clear and Convincing Evidence:
- The Court adopts the higher evidentiary standard (not just preponderance). This is because Rule 60(b)(3) undermines the finality of judgments and must be reserved for serious, proven misconduct.
Prevention of Full and Fair Presentation:
- Fraud must go beyond a mere lie; it must materially impede the movant’s ability to litigate or negotiate the case.
- Here, the undisclosed $4 million CAD policy literally doubled the available insurance coverage and dramatically changed the value of the Canadian Property as a marital asset.
- The Court finds that had Husband known the truth, the property division negotiations would almost certainly have proceeded differently.
Scienter (Knowing and Intentional Misrepresentation):
- The misrepresentation must not be accidental.
- Wife’s repeated, affirmative statements that $2 million CAD was the only policy, combined with her silence about the $4 million CAD policy, satisfy this requirement.
- Wife’s affidavit never directly denied the existence of a second policy or claimed that she was mistaken; she only argued that Husband knew the claim value was unsettled and did not investigate enough.

Taken together, these elements justify disturbing the otherwise final divorce decree.

2. The Continuing Duty to Disclose Once Discovery Begins

The Court’s analysis underscores the concept of a continuing duty of disclosure in divorce litigation:

When formal discovery is underway, each party must supplement responses and keep the other side apprised of:
- material changes in asset values,
- newly discovered assets, and
- information that would render previous responses incomplete or misleading.
Wife produced one policy and actively represented that there were no others, while knowing (or at least, the record supports finding that she knew) that a different policy with higher coverage limits applied.
This is more than silence—it is affirmative misrepresentation that materially altered the perceived financial landscape at the negotiation table.

3. Reconciling Arm’s-Length Negotiation with the Ban on Concealment

The Court harmonizes Jeffries and Pekelder as follows:

Divorcing spouses:
- are generally treated as parties negotiating at arm’s length,
- do not owe each other the heightened duties of fiduciaries, but
- still may not hide assets or lie about them.
Due diligence is not a license:
- A non-disclosing spouse cannot shield fraud behind the other spouse’s alleged failure to dig deeper when that other spouse has already:
  - used formal discovery,
  - persistently requested documents, and
  - reasonably relied on what was provided.

Thus, the Court firmly rejects Wife’s attempt to recast the case as Husband’s failure to investigate rather than her duty to disclose.

4. Relief: Property Division and the Effect of the Supersedeas Order

The Court’s remedial analysis is narrower:

The trial court relied on:
- the parties’ contract (stipulation) that undisclosed property would be shared equally, and
- SDCL 25‑4‑77 (authorizing the court to assign property not disposed of by the decree).
It ordered a 50/50 split of insurance proceeds over $2 million CAD and placed those proceeds in trust.
However, after Wife appealed, the court issued a supersedeas order allowing:
- use of insurance proceeds to rebuild the house,
- prohibition on waste, and
- deposit of any leftover proceeds into counsel’s trust account.

By the time the Supreme Court decided the case, it did not know:

How much of the insurance money had been spent,
What the new structure was worth, or
Whether any “excess” funds remained.

Therefore, the Court treats the specific distribution order (equal division of proceeds above $2 million CAD) as potentially moot and remands for:

A fresh, equitable division of assets in light of:
- the rebuilt property,
- the contractual obligations to the builder, and
- any remaining proceeds.

Importantly, the Court does not adopt Wife’s proposed bright-line rule that property casualty insurance proceeds to replace marital property must always be treated as inseparable from the underlying property. Instead, it leaves that question open and focuses on equitable division under the facts at hand.

C. Potential Impact on Future Cases and Areas of Law

1. Family Law and Divorce Settlements

The most direct impact will be on divorce litigation and marital settlement agreements:

Stronger incentive for full disclosure:
- Parties are now on clear notice that intentional concealment or misrepresentation of assets can lead to:
  - reopening of otherwise final decrees,
  - exposure to fee awards, and
  - judicial reallocation of property under SDCL 25‑4‑77.
Increased importance of disclosure clauses:
- Provisions like Paragraph 4 in the Trumble stipulation (sharing undisclosed property equally) will be given effect and can serve as the contractual basis for later adjustments.
Guidance on due diligence:
- Spouses fulfill their duty by:
  - retaining counsel,
  - issuing formal discovery, and
  - insisting on document production.
- They are not expected to do the impossible, such as obtaining third-party insurer records when blocked by lack of authorization; in such situations they may rely on sworn and represented disclosures.

2. Civil Litigation Practice Generally

Outside family law, the case clarifies Rule 60(b)(3) across civil practice:

Adopted standard for fraud between parties:
- Lawyers now have a well-defined test for when a judgment can be set aside due to the other side’s misconduct.
- This affects any civil case where one party might conceal evidence or misrepresent material facts during litigation.
Affidavits on motion practice:
- While permitted, affidavit-only adjudication is disfavored when material facts are disputed.
- Attorneys should consider pressing for evidentiary hearings in close cases to develop a fuller record and preserve issues for appeal.

3. Cross-Border Property and Insurance Issues

Although the property was in Canada and the insurance proceeds were denominated in Canadian dollars, the Court treated the insurance asset like any other marital property subject to South Dakota’s equitable division rules. Practitioners should note:

Foreign property and insurance claims must be fully disclosed.
Differences in foreign insurance practice or currency denomination will not shield assets from disclosure or equitable distribution.

V. Complex Concepts Explained

1. Rule 60(b) and SDCL 15‑6‑60(b)(3)

Rule 60(b) allows a court to grant relief from a final judgment or order in limited, specified circumstances—such as mistake, newly discovered evidence, or fraud. SDCL 15‑6‑60(b)(3) addresses:

“Fraud (whether heretofore denominated intrinsic or extrinsic), misrepresentation, or other misconduct of an adverse party.”

Key points:

It is an extraordinary remedy, not a routine appeal substitute.
Motions must generally be brought within one year of the judgment when based on fraud.
The purpose is to balance the finality of judgments with the need to remedy serious injustices.

2. “Fraud Upon the Court” vs. “Fraud Between the Parties”

Fraud upon the court:
- Serious misconduct that corrupts the judicial process itself.
- Examples: bribing a judge, bribing jurors, or an attorney colluding to create fake evidence.
- These are rare, extreme cases and can sometimes be addressed without time limits.
Fraud between the parties:
- One litigant lies to or hides information from the other, which affects the outcome.
- This is what happened in Trumble.
- Such fraud is serious but does not necessarily corrupt the court itself.

3. “Clear and Convincing Evidence”

“Clear and convincing” is a higher standard than “more likely than not,” but lower than “beyond a reasonable doubt.” It means the evidence must make the truth of the claim:

“Highly probable” or “reasonably certain,” and
Leaving the factfinder with a firm belief or conviction that the allegation is true.

4. “Scienter”

Scienter is a legal term meaning the defendant acted with:

knowledge of the falsehood, and
intent to deceive or mislead.

In other words, it wasn’t an honest mistake or misunderstanding; the person knew what they were saying or omitting was misleading and did so deliberately.

5. “Supersedeas Undertaking”

When a party appeals a judgment, a “supersedeas bond” or “undertaking” is sometimes required to:

Pause enforcement of the judgment during appeal (a “stay”), and
Protect the other party from loss if the judgment is ultimately affirmed.

In this case:

Instead of a cash bond, the court crafted a functional undertaking:
- Ordering that the insurance proceeds be used to rebuild.
- Preventing waste.
- Requiring any leftover funds to be held in trust.

6. “Mootness” and “Justiciable Controversy”

A case is moot if:
- The court’s decision will no longer affect the parties’ rights in a practical way.
A justiciable controversy is a live, concrete dispute over legal rights that a court’s decision can resolve.

Because the insurance proceeds had been directed into reconstruction, the prior order about splitting “excess” proceeds might no longer be directly applicable, prompting remand.

VI. Conclusion: Key Takeaways and Broader Significance

Trumble v. Trumble is an important decision in South Dakota family law and civil procedure, for several reasons:

Formal Adoption of the Federal Rule 60(b)(3) Standard for Fraud Between Parties:
- Fraud, misrepresentation, or misconduct justifying relief must be:
  - Proven by clear and convincing evidence,
  - Shown to have prevented a full and fair presentation of the case, and
  - Knowing and intentional (scienter).
Reaffirmation of the Duty of Full Disclosure in Divorce:
- Even though divorcing spouses are at arm’s length, they still may not hide or misrepresent assets.
- Once discovery begins, there is a continuing obligation to fully and accurately disclose marital assets and material changes.
Clarification of Due Diligence: No Shield for Concealment:
- A spouse who:
  - Retains counsel,
  - Uses formal discovery, and
  - Reasonably relies on the other side’s representations
  has exercised sufficient diligence.
- The other spouse cannot avoid the consequences of fraud by blaming the victim for not doing more.
Procedural Guidance on Affidavits and Standards of Review:
- Factual findings based on documentary evidence are subject to clear error review under SDCL 15‑6‑52(a), as amended.
- Affidavit-only practice is disfavored where significant factual disputes exist, but is permissible where both parties acquiesce and the record is adequate.
Flexible, Equitable Remedies in Light of Changed Circumstances:
- The Court affirms Rule 60(b) relief but remands for a fresh equitable division in light of:
  - Rebuilding of the home,
  - Use of insurance proceeds, and
  - Any remaining funds.

In sum, Trumble sends a clear message: in divorce and other civil cases, parties who conceal or misrepresent significant assets during negotiation and discovery risk having the judgment reopened under Rule 60(b)(3) and facing corrective reallocation of property and fee awards. The decision fortifies the integrity of settlement processes while preserving the judiciary’s ability to correct outcomes tainted by fraud.

Fraud Between Spouses Under Rule 60(b)(3): Trumble v. Trumble and the Duty of Full Asset Disclosure in Divorce Settlements