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In an opinion issued on November 10, 2026, the Texas Fourteenth Court of Appeals upheld the divorce property division in Joshua Peacock v. Stephanie Ann Samples, docket number 14-25-00875-CV. The appeals court found sufficient evidence supporting the lower court’s decisions, including its award of the $411,000 rental house to his former wife, Stephanie Ann Samples, and a $175,000 equalisation payment. Peacock and Samples married in 2016 and had three children together. Samples hired business valuation expert Jeremy Robin, who estimated the dealership’s worth at between $675,000 and $972,000. Peacock, meanwhile, claimed that it was worth only $150,000 at the time of the divorce trial.
A divorce can become particularly complicated when a couple disagrees over whether property acquired during their marriage belongs to one spouse individually or forms part of their shared marital estate. In Texas, a dispute over a rental house allegedly gifted by a father and the valuation of a family-owned used-car dealership became central to a divorce appeal involving a couple married for eight years and their three children. The ruling , available on Justia, rejected Joshua Peacock’s arguments that the rental house was his separate property and that the family dealership had been incorrectly valued. During their marriage, Samples worked as a certified teacher but became a stay-at-home mother after the children were born. She later returned to employment as a substitute teacher and also undertook data-entry and hat-design work. Peacock worked in his family’s used-car business and was the primary income earner. The family lived in a house owned by his mother. However, the property was transferred directly from its previous owner to Peacock. His father had never held the title, and the deed was not presented as evidence during the trial. Samples also testified that she had not seen documents establishing that the property was a gift. The other major disagreement concerned the family’s used-car dealership, which Peacock had acquired from his father during the marriage. Both parties treated the business as community property, but they disagreed over its value. Overall, the ruling reinforces that claiming a family property was gifted during marriage is not enough to establish separate ownership under Texas law. Documentary evidence and proof of the donor’s intention are important, while a court can rely on supported expert valuations when dividing a marital business.