Mandatory Detailed Findings under Ferguson: Sistrunk v. Sistrunk Clarifies Mississippi Equitable Distribution Requirements

Introduction

Sistrunk v. Sistrunk, decided April 3, 2025 by the Supreme Court of Mississippi, addresses the chancery court’s failure to make detailed factual findings under the established Ferguson framework (Ferguson v. Ferguson, 639 So. 2d 921 (Miss. 1994)) when dividing marital assets in a divorce. The appeal was brought by Nancy Johnson Sistrunk against Carlos Leslie Sistrunk following a chancery court decree that granted a divorce but—according to the Supreme Court—did not substantively consider key statutory and equitable factors in its equitable distribution analysis. By reversing and remanding, the high court reinforces the requirement that trial judges must make specific, supported findings on each applicable Ferguson factor.

Summary of the Judgment

In its opinion, the Supreme Court of Mississippi:

Held that the trial court’s written order merely listed the Ferguson factors without making individualized findings or explaining the weight given to each.
Determined that many factual findings were unsupported by substantial evidence, including the notion that the parties’ vastly different incomes somehow “offset” each other.
Reversed the chancery court’s division of marital property and related equitable determinations (alimony, child support for a disabled adult child, attorneys’ fees), and remanded for entry of a new decree with detailed Ferguson‐factor findings.
Clarified that chancellors need not discuss factors inapplicable to the case (Lee v. Lee, 78 So. 3d 326 (Miss. 2012)), but must address all relevant factors with specificity and evidentiary support.

Analysis

1. Precedents Cited

Ferguson v. Ferguson (639 So. 2d 921 (Miss. 1994)) – Established eight-factor framework for equitable distribution in Mississippi divorces.
Armstrong v. Armstrong (618 So. 2d 1278 (Miss. 1993)) – Identified factors for alimony awards.
Lowrey v. Lowrey (25 So. 3d 274 (Miss. 2009)) – Emphasized trial court’s duty to make factual findings on each Ferguson factor.
Lee v. Lee (78 So. 3d 326 (Miss. 2012)) – Held that chancellors need not address inapplicable Ferguson factors but cannot merely recite them.
Dillon v. Dillon (498 So. 2d 328 (Miss. 1986)) – Recognized chancery courts’ broad equitable power to award attorneys’ fees.
Smith v. Smith (607 So. 2d 122 (Miss. 1992)) – Confirmed that courts may grant relief supported by proof, even if not specifically pleaded, so long as due process is observed.

2. Legal Reasoning

The Supreme Court’s opinion focuses on the proper application of the Ferguson factors in equitable distribution of marital property. Under Mississippi law, a chancery court must:

Identify each Ferguson factor applicable to the parties’ circumstances.
Make written findings of fact on the evidence presented for every applicable factor.
Explain how the findings support the division of property and any offsetting considerations.
Avoid findings unsupported by substantial evidence, including benchmarks such as asset values and income disparities.

In Sistrunk, the trial court listed the Ferguson factors without tying them to evidentiary findings. It also made several conclusions—such as offsetting income levels and the parity of asset dissipation—that the record did not support. Such omissions and unsupported findings constituted an abuse of discretion and warranted reversal under the “manifestly wrong” and “clearly erroneous” standards (Gerty v. Gerty, 265 So. 3d 121 (Miss. 2018)).

3. Impact

Sistrunk v. Sistrunk underscores and refines the chancellor’s obligations in Mississippi domestic-relations litigation:

Heightened Scrutiny of Factual Findings: Trial judges must demonstrate, factor by factor, how the evidence supports their conclusions.
Consistency and Transparency: Parties and appellate courts gain clarity on why and how assets were divided.
Guidance for Practitioners: Lawyers defending or appealing property divisions will craft arguments and orders that precisely track Ferguson’s framework.
Broader Equitable Discretion: While maintaining flexibility, chancellors cannot shortcut the analysis by broad statements of “equity” or “fairness.”

Complex Concepts Simplified

Equitable Distribution vs. Equal Distribution: Mississippi law mandates a fair (equitable) split, not always a 50/50 split. “Equitable” depends on multiple factors—financial contributions, future needs, dissipation of assets, etc.—rather than a simple mathematical division.
Ferguson Factors: Eight criteria ranging from economic contributions to emotional value. Courts must weigh and explain each relevant factor in writing.
Substantial Evidence Standard: Findings must be backed by credible, probative evidence in the record—trial testimony, appraisals, financial statements—not mere judicial intuition.
Remand Procedures: When a court reverses and remands, the lower court must correct identified errors—here, by conducting a new equitable division analysis with proper findings.

Conclusion

Sistrunk v. Sistrunk reinforces the imperative that chancery courts in Mississippi divorce cases engage in a structured, transparent Ferguson‐factor analysis. By reversing and remanding for detailed findings supported by substantial evidence, the Supreme Court of Mississippi ensures that equitable distribution orders are both fair and defensible on appeal. Going forward, practitioners must meticulously document how each factor influences the division of assets, thereby upholding both the spirit and letter of Mississippi’s domestic-relations jurisprudence.