Rhode Island Divorce and Family Law: Important Supreme Court Decisions and Legal Developments Through 2026

By Ryanna T. Capalbo, Esq. | Bilodeau Capalbo, LLC | October 2026

Rhode Island divorce and family law continues to evolve through decisions of the Rhode Island Supreme Court, even when the underlying statutes remain substantially unchanged. Recent appellate decisions have addressed important questions involving the valuation and division of marital property, ownership interests in closely held businesses, inherited assets, retirement benefits, child custody, relocation, child support, and the enforcement of marital settlement agreements.

For individuals considering divorce, these decisions demonstrate that the outcome of a case often depends upon detailed financial evidence, the language of governing agreements, the classification of property, and the particular circumstances presented to the Family Court.

For business owners, professionals, executives, and individuals with substantial marital estates, recent developments are particularly significant. Decisions concerning shareholder agreements, stock options, restricted stock units, and inherited property illustrate how legal and financial considerations intersect in divorce litigation.

At Bilodeau Capalbo, LLC, our attorneys represent clients in contested and uncontested divorce proceedings, complex equitable distribution disputes, child custody matters, support proceedings, and post-divorce litigation.

This article examines important Rhode Island Supreme Court decisions from 2023 through 2026 and explains their significance for individuals and families navigating divorce and related proceedings.

For information about legal representation, visit our Rhode Island Divorce Lawyers page.

Equitable Distribution of Marital Property in Rhode Island

Rhode Island follows the principle of equitable distribution under R.I. Gen. Laws § 15-5-16.1.

Unlike an automatic equal division of marital assets, equitable distribution requires the Family Court to identify property subject to assignment, consider the statutory factors, and determine an equitable allocation based upon the circumstances.

The statutory analysis may involve the duration of the marriage, the parties’ respective financial and nonfinancial contributions, their conduct, earning capacities, economic circumstances, and other legally relevant considerations.

Disputes frequently arise concerning whether particular assets are marital property, how they should be valued, and whether certain circumstances justify an unequal distribution.

Recent Rhode Island Supreme Court decisions have addressed these issues in the context of closely held businesses, retirement benefits, inherited property, trusts, and employment-related equity compensation.

Learn more about our Rhode Island Property Division Practice.

Business Valuation in Divorce: Cronan v. Cronan

Business ownership interests can present substantial valuation disputes during divorce proceedings.

A spouse may own shares in a closely held corporation, a membership interest in a limited liability company, a professional practice, or another enterprise whose value is not readily established through publicly available market information.

In Cronan v. Cronan, 307 A.3d 183 (R.I. 2024), the Rhode Island Supreme Court considered the valuation of a spouse’s ownership interest in a closely held medical practice.

The Family Court valued the interest at $366,200 based upon the terms of a binding shareholder agreement rather than adopting the substantially higher valuation advanced by the opposing party.

The Supreme Court affirmed that determination in light of the contractual provisions and evidence presented.

The decision illustrates that shareholder agreements, operating agreements, and contractual buyout restrictions may be important evidence when valuing business interests in divorce.

However, Cronan does not establish that every contractual buyout price automatically determines the value of a business interest in every divorce proceeding.

The valuation analysis depends upon the governing agreements, the circumstances of ownership, the evidence presented, and the applicable equitable distribution principles.

Practical Implications for Business Owners

Business owners contemplating marriage or divorce should understand how existing ownership agreements may affect the valuation of their interests.

Relevant documents may include shareholder agreements, operating agreements, partnership agreements, buy-sell provisions, financial statements, and other contractual arrangements affecting ownership and transfer rights.

Business valuations may also involve disputed goodwill, earnings, liabilities, capitalization, and the opinions of valuation experts.

Bilodeau Capalbo, LLC combines experience in family law and Business Law when representing clients in disputes involving closely held companies and substantial business interests.

Stock Options, Restricted Stock Units and Valuation Dates: Hogan v. Wong

Employment-related equity compensation can create significant disputes in high-net-worth divorce proceedings.

Stock options, restricted stock units (RSUs), deferred compensation, and performance-based equity awards may have substantial value but remain subject to vesting schedules, employment conditions, transfer restrictions, and future market fluctuations.

In Hogan v. Wong, 360 A.3d 55 (R.I. 2026), the Rhode Island Supreme Court addressed the classification, valuation, and assignment of stock options and restricted stock units arising from employment compensation.

The Court affirmed the Family Court’s use of the parties’ separation date to value certain vested equity awards rather than the date of trial, based upon compelling circumstances established in the case.

The Supreme Court also upheld the assignment of unvested stock options and RSUs to the employee spouse under the particular circumstances presented.

The decision is important because the date used to value employment-related equity compensation can materially affect the amount included in the marital estate.

Where the underlying company’s stock price changes significantly between separation and trial, the choice of valuation date may produce substantially different results.

Nevertheless, Hogan does not establish that unvested stock options and RSUs are automatically excluded from equitable distribution or that separation-date valuation is appropriate in every case.

Practical Implications for Executives and Professionals

Individuals receiving stock options, RSUs, restricted shares, or other equity compensation should carefully examine the terms of their employment and compensation agreements.

Important considerations may include when the awards were granted, when they vest, whether continued employment is required, the purpose of the compensation, and the evidence supporting the proposed valuation date.

These disputes may require financial experts familiar with equity compensation, valuation methodology, and the treatment of contingent employment benefits.

Learn more about our High Net Worth Divorce Practice.

Retirement Benefits and Financial Disclosure: DiDonato v. DiDonato

Retirement benefits frequently represent a substantial portion of a marital estate.

Pensions, retirement accounts, deferred compensation plans, and other employment-related benefits may raise questions concerning classification, valuation, timing, and implementation of property division awards.

In DiDonato v. DiDonato, 295 A.3d 828 (R.I. 2023), the Rhode Island Supreme Court addressed the treatment of pension benefits accumulated during marriage, the classification of property held in trust, and the consequences of inadequate financial disclosure.

The decision illustrates that pension interests earned during marriage may be subject to equitable distribution and that a spouse’s placement of marital assets into a trust does not necessarily remove those assets from the marital estate.

The Court also upheld a substantial monetary sanction arising from repeated failures to disclose financial holdings during the proceedings.

Financial Disclosure and Concealed Assets

Divorce proceedings require careful identification and evaluation of the parties’ financial circumstances.

Disputes may involve undisclosed bank accounts, investment holdings, business interests, trusts, retirement assets, and financial transactions.

Where substantial assets are involved, financial investigation may require analysis of tax returns, bank statements, investment records, ownership agreements, and other documentation.

DiDonato demonstrates the importance of complying with financial disclosure obligations and the potential consequences of failing to provide complete and accurate financial information.

Our attorneys represent clients in divorce litigation involving disputed financial disclosures, trusts, business interests, and allegations of concealed marital assets.

Pension Division After Divorce: Codere-Wilson v. Wilson

Disputes concerning retirement benefits may continue long after the entry of a final divorce judgment.

A marital settlement agreement may establish rights to pension benefits that require additional documentation or judicial proceedings before the division can be implemented.

In Codere-Wilson v. Wilson, 359 A.3d 76 (R.I. 2026), the Rhode Island Supreme Court addressed the enforcement of pension division provisions contained in a marital settlement agreement incorporated but not merged into a divorce judgment.

The Court permitted enforcement of the agreement through a subsequent qualified domestic relations order.

The decision illustrates the distinction between enforcing an existing contractual obligation and attempting to modify a final property assignment.

Why the Language of a Settlement Agreement Matters

Retirement provisions should identify the benefits subject to division and address the terms necessary to implement the parties’ agreement.

Disputes may arise concerning the interpretation of settlement language, survivor benefits, pension commencement dates, and the preparation of domestic relations orders.

The decision underscores the importance of careful drafting and review of marital settlement agreements, particularly where substantial retirement benefits are involved.

Learn more about our Property Division and Retirement Asset Representation.

Inherited Property and Transmutation: Constantino v. Orban

Inherited property and assets acquired before marriage frequently create disputes concerning whether the property is subject to equitable distribution.

R.I. Gen. Laws § 15-5-16.1 addresses the treatment of certain property acquired by gift or inheritance.

However, disputes may arise when inherited property is transferred into joint ownership, funds are commingled, marital resources are used in connection with separately owned property, or one spouse contends that the owner intended to convert the property into marital property.

In Constantino v. Orban, 359 A.3d 822 (R.I. 2026), the Rhode Island Supreme Court considered whether foreign real estate acquired through inheritance or gift had become marital property.

The Court affirmed the determination that the disputed properties remained nonmarital where the evidence did not establish an objectively manifested intention to convert them into marital property.

The litigation involved arguments concerning joint tax reporting and the payment of certain expenses associated with the properties.

Protecting Inherited and Premarital Property

The classification of inherited property depends upon the applicable statutory provisions and evidence concerning ownership, financial transactions, and the parties’ conduct.

Joint ownership, commingling of funds, and contributions of marital resources may create questions concerning the treatment of previously separate property.

However, these circumstances do not eliminate the need for a legally supported analysis of whether an intention to convert the property has been objectively manifested.

Individuals seeking to protect inherited or premarital property should maintain accurate records concerning acquisition, ownership, financial transfers, and subsequent treatment.

Our attorneys represent clients in disputes concerning inherited property, premarital assets, real estate, and the classification of property in divorce.

Alimony and Financial Independence: Cronan v. Cronan

Alimony is governed by R.I. Gen. Laws § 15-5-16.

Rhode Island alimony is generally rehabilitative in purpose, although the statute permits other arrangements under appropriate circumstances.

Relevant considerations may include the duration of the marriage, financial resources, earning capacity, employment history, health, age, and the financial consequences of equitable distribution.

In addition to addressing business valuation, Cronan v. Cronan, 307 A.3d 183 (R.I. 2024), considered an alimony determination.

The Rhode Island Supreme Court affirmed the Family Court’s denial of alimony based upon the evidence concerning the requesting spouse’s financial circumstances and ability to support herself.

The decision illustrates the importance of presenting evidence concerning financial need, earning capacity, available resources, and the statutory considerations governing alimony.

Alimony determinations depend upon the facts of each case. Neither the existence of a substantial marital estate nor a disparity in income automatically determines whether alimony will be awarded.

Learn more about our Rhode Island Spousal Support and Alimony Practice.

Child Custody and Required Judicial Findings: Conway v. Orenberg

Child custody disputes require consideration of the child’s best interests.

Rhode Island courts evaluate the evidence concerning parental relationships, the child’s needs, stability, proposed living arrangements, and other relevant circumstances.

In Conway v. Orenberg, 349 A.3d 250 (R.I. 2026), the Rhode Island Supreme Court addressed the adequacy of the Family Court’s findings supporting a primary placement determination.

The Court vacated the challenged placement order because the record did not contain sufficient findings supporting the necessary best-interests analysis.

The decision illustrates the importance of developing a factual record that permits meaningful judicial consideration and appellate review.

A custody determination must be grounded in the evidence and the applicable legal standards rather than an unsupported assumption about the arrangement that should govern.

Practical Implications for Parents

Parents involved in contested custody proceedings should understand the importance of evidence concerning their children’s needs, living arrangements, educational circumstances, parental responsibilities, and relationships with each parent.

Our attorneys represent parents in custody negotiations, contested hearings, and proceedings involving the modification or enforcement of parenting arrangements.

Learn more about our Child Custody and Visitation Practice.

Child Relocation and Interstate Custody Disputes

Relocation disputes arise when a parent seeks to move with a child to another city, state, or country.

These proceedings can present difficult questions concerning the child’s best interests, the reasons for relocation, the relationship with each parent, educational opportunities, family support, and the feasibility of maintaining meaningful parenting time.

Rhode Island courts consider the relevant factors established in Dupre v. Dupre, 857 A.2d 242 (R.I. 2004).

Recent Rhode Island Supreme Court decisions demonstrate that relocation determinations depend upon the evidence and particular circumstances.

In Dawson v. Ojeda, 303 A.3d 569 (R.I. 2023), the Supreme Court affirmed a relocation determination involving a move to Massachusetts.

In Mendez v. Arancibia, 336 A.3d 60 (R.I. 2025), the Court addressed an international relocation involving Bolivia.

Conversely, in Leon v. Krikorian, 271 A.3d 985 (R.I. 2022), the Supreme Court affirmed the denial of a requested relocation to Florida.

These decisions illustrate that relocation is neither automatically permitted nor automatically prohibited.

The controlling consideration remains the child’s best interests as evaluated under the applicable legal framework.

Interstate and international custody disputes may also involve jurisdictional questions requiring analysis of the Uniform Child Custody Jurisdiction and Enforcement Act and other applicable laws.

Child Support, Business Income and Earning Capacity: Mezini v. Mezini

Child support determinations involving business owners and self-employed parents can present complicated financial questions.

A business owner may receive compensation through salary, distributions, guaranteed payments, bonuses, or other financial arrangements.

Disputes may concern the parent’s actual earnings, earning capacity, business expenses, and whether reported income accurately reflects the parent’s financial circumstances.

In Mezini v. Mezini, 268 A.3d 1171 (R.I. 2022), the Rhode Island Supreme Court addressed a child support determination involving disputed income and earning capacity.

The Court affirmed the Family Court’s determination based upon financial evidence and credibility findings concerning the husband’s earnings and business-related financial circumstances.

The decision illustrates that child support determinations may require examination of financial records and evidence of earning capacity rather than reliance solely upon a parent’s characterization of reported income.

Business tax returns, financial statements, payroll records, distributions, and other documents may become important evidence in these disputes.

Child Support Worksheets and Attorney Authority: Conway v. Orenberg

Conway v. Orenberg, 349 A.3d 250 (R.I. 2026), also addressed a child support guideline worksheet signed by counsel and entered as an order of the Family Court.

The Supreme Court’s decision illustrates the importance of reviewing proposed support calculations and understanding the legal consequences of documents submitted to the court.

Parents should carefully review income figures, applicable deductions, expenses, and other information used in calculating support.

The case also highlights the significance of attorney authority and the procedural circumstances surrounding the entry of support orders.

R.I. Gen. Laws § 15-5-16.2 governs child support determinations and provides the statutory framework for applying the Rhode Island child support guidelines.

Our attorneys represent parents seeking, contesting, modifying, and enforcing child support obligations.

Learn more about our Rhode Island Child Support Practice.

Prenuptial and Postnuptial Agreements in Rhode Island

Prenuptial and postnuptial agreements may have significant consequences for the division of property and financial obligations in divorce proceedings.

Rhode Island’s Uniform Premarital Agreement Act, R.I. Gen. Laws Chapter 15-17, governs premarital agreements.

Disputes may concern enforceability, financial disclosure, execution circumstances, interpretation of contractual provisions, and the treatment of property under the agreement.

Postnuptial agreements may present different contractual and legal questions.

In McCollum v. McCollum, 287 A.3d 26 (R.I. 2023), the Rhode Island Supreme Court addressed issues involving a postnuptial agreement, attorney’s fees, and the relationship between contractual choice-of-law provisions and Rhode Island divorce proceedings.

The decision illustrates the importance of evaluating marital agreements in conjunction with the applicable domestic relations law and procedural requirements.

Our attorneys assist clients in reviewing, negotiating, preparing, and litigating disputes concerning prenuptial and postnuptial agreements.

What These Rhode Island Supreme Court Decisions Mean for Divorcing Spouses

The recent decisions of the Rhode Island Supreme Court illustrate several recurring principles in divorce and family law litigation.

First, contractual documents can significantly affect financial outcomes. Shareholder agreements, operating agreements, marital settlement agreements, and employment compensation plans may become important evidence in determining the value and treatment of disputed assets.

Second, financial disclosure and documentary evidence are essential. Disputes involving concealed assets, trusts, business income, and retirement benefits often depend upon careful investigation of financial records and ownership arrangements.

Third, equitable distribution requires analysis of the particular assets and circumstances presented. The classification of inherited property, treatment of employment-related equity compensation, and selection of valuation dates cannot be resolved through automatic rules applicable to every divorce.

Fourth, child custody and support determinations must be supported by the governing legal standards and relevant evidence. The financial circumstances of parents, children’s needs, and the adequacy of judicial findings can have substantial consequences.

Finally, the language of settlement agreements matters. Carefully drafted agreements may prevent future disputes, while ambiguous provisions can result in litigation years after a divorce judgment has entered.

Representation in Complex Rhode Island Divorce and Family Law Matters

Bilodeau Capalbo, LLC represents individuals in divorce and family law matters involving substantial financial interests, closely held businesses, commercial and residential real estate, trusts, retirement benefits, alimony, child custody, parenting time, and child support.

Our family law practice is led by attorney Ryanna T. Capalbo.

The firm’s experience in family law, business law, real estate, and civil litigation provides additional perspective when divorce proceedings involve complex financial arrangements, disputed business valuations, commercial property, executive compensation, retirement assets, and the classification of marital and nonmarital property.

These overlapping areas of law can be particularly important in high-net-worth divorce proceedings, where the financial consequences of equitable distribution may extend beyond the immediate division of assets and affect business operations, investment holdings, retirement planning, and future financial security.

Our attorneys represent clients in contested and uncontested divorce proceedings, financial discovery disputes, equitable distribution, alimony, child custody, parenting time, child support, and post-divorce litigation.

We recognize that family law matters require careful consideration of both the applicable legal standards and the practical consequences of the decisions being made. Our approach emphasizes thorough preparation, detailed factual investigation, informed legal analysis, and strategies tailored to each client’s circumstances.

Where appropriate, we work toward negotiated resolutions that address our clients’ legal and financial interests. When disputes cannot be resolved through negotiation or mediation, our attorneys are prepared to represent clients in contested proceedings before the Rhode Island Family Court.

Why Recent Rhode Island Family Law Decisions Matter

The Rhode Island Supreme Court decisions discussed in this article demonstrate that the outcome of divorce and family law litigation frequently depends upon the particular evidence presented and the application of established legal principles to complicated factual circumstances.

For individuals who own closely held businesses, the terms of shareholder agreements and other ownership documents may substantially affect the valuation of marital assets.

For executives and professionals receiving stock options, restricted stock units, or deferred compensation, the classification and valuation of employment-related benefits may have significant consequences for equitable distribution.

For spouses who own inherited or premarital property, maintaining accurate records concerning acquisition, ownership, and subsequent treatment may be important in disputes involving the classification of separate property.

For individuals with pension and retirement benefits, carefully drafted marital settlement agreements and appropriate domestic relations orders can be essential to implementing and enforcing property division obligations.

For parents involved in child custody or relocation disputes, the evidence concerning the best interests of their children and the adequacy of the Family Court’s findings can be critical.

For parents involved in child support proceedings, accurate financial information, appropriate guideline calculations, and careful consideration of earning capacity can significantly affect the resulting obligations.

These decisions also illustrate the importance of identifying legal and financial issues early in the proceedings, preserving relevant evidence, complying with financial disclosure requirements, and obtaining appropriate legal advice before entering binding agreements.

Learn More About Rhode Island Divorce and Family Law

Bilodeau Capalbo, LLC provides representation in a broad range of divorce and family law matters. Additional information about specific legal issues is available through the following practice-area pages:

• Rhode Island Divorce Lawyers — Contested and uncontested divorce, equitable distribution, alimony, custody, and divorce litigation.
• High Net Worth Divorce — Complex marital estates, business ownership, executive compensation, investment assets, and substantial financial disputes.
• Property Division and Equitable Distribution — Marital and nonmarital property, inherited assets, retirement benefits, real estate, and business valuations.
• Child Custody and Visitation — Legal custody, physical placement, parenting time, relocation, and contested custody proceedings.
• Child Support — Child support calculations, business income, earning capacity, modifications, and enforcement.
• Spousal Support and Alimony — Financial support, earning capacity, alimony determinations, and post-divorce disputes.
• Rhode Island Family Law — An overview of the firm’s divorce and domestic relations practice.

Consult a Rhode Island Divorce and Family Law Attorney

If you are considering divorce, involved in a dispute concerning marital property, or facing questions involving business valuations, retirement assets, alimony, child custody, or child support, Bilodeau Capalbo, LLC can assist you in evaluating your legal rights and options.

Our attorneys represent individuals in contested and uncontested divorce proceedings, complex financial litigation, high-net-worth divorce matters, custody disputes, support proceedings, and post-divorce litigation.

The decisions discussed in this article illustrate that even established principles of Rhode Island family law may require detailed factual analysis and careful consideration of recent appellate authority.

Whether your matter involves a negotiated marital settlement agreement or contested proceedings before the Family Court, our attorneys can review your circumstances, explain the legal issues involved, and discuss an appropriate course of action.

To arrange a consultation, call 401-300-4055 or contact Bilodeau Capalbo, LLC online.

Bilodeau Capalbo, LLC
1350 Division Road, Suite 102
West Warwick, Rhode Island 02879
Telephone: 401-300-4055

About the Author

Ryanna T. Capalbo, Esq., is a partner at Bilodeau Capalbo, LLC and leads the firm’s family law practice. Her practice includes divorce, child custody, property division, alimony, child support, and contested litigation.

Attorney Capalbo has also successfully argued before the Rhode Island Supreme Court, including the adverse possession appeal in Union Cemetery Burial Society of North Smithfield v. Foisy, 292 A.3d 1205 (R.I. 2023).

Her practice reflects the firm’s commitment to careful legal analysis, thorough preparation, and effective advocacy in matters involving significant personal, financial, and property interests.

Legal Disclaimer

This article is provided for general informational purposes only and does not constitute legal advice or create an attorney-client relationship. The application of Rhode Island law depends upon the particular facts and circumstances of each case. Statutes, court rules, and judicial interpretations may change, and readers should consult qualified legal counsel concerning their individual circumstances.

Legal developments discussed through October 2026.