The North Carolina Court of Appeals’ decision in Biddle v. Biddle, No. COA25-581 (Apr. 15, 2026), provides a detailed roadmap for how trial courts must handle stipulations, classification of property, and burdens of proof in equitable distribution cases. The opinion is especially useful for practitioners navigating complex financial estates with pretrial orders.

At its core, Biddle reinforces a fundamental principle: binding stipulations in a pretrial order strictly limit the issues a trial court may decide—and courts may not “do equity” by disregarding those stipulations during classification or valuation.

1. Stipulations Are Binding—and Enforceable

The central holding concerns the trial court’s treatment of the parties’ stipulated classification of a townhome as marital property. Despite that stipulation, the trial court attempted to “trace out” the husband’s separate contributions and classify part of the property as separate.

The Court of Appeals reversed, holding that when parties enter into clear, definite stipulations regarding classification and value, those stipulations are binding on both the parties and the court unless properly set aside. Here, no motion was made to set aside the stipulation, and therefore the trial court erred.

Importantly, the court emphasized that stipulations narrow the litigation: once classification and value are agreed upon, the trial court’s role is limited to distribution—not reclassification. The court memorably noted that the trial judge “put the cart before the horse” by trying to reach an equitable outcome at the wrong stage.

2. Equity Belongs in Distribution, Not Classification

A key takeaway from Biddle is the reaffirmation of the three-step equitable distribution process:

1. Classify property
2. Value property
3. Distribute property

The trial court attempted to account for the husband’s separate contributions during classification (step one/two), rather than as a distributional factor under N.C. Gen. Stat. § 50-20(c) (step three). The Court of Appeals clarified that this was improper.

The correct approach: honor the stipulation (classify as marital), value the asset accordingly, and then consider unequal distribution if justified.

3. Trial Courts Must Honor Trial Stipulations

The court also vacated the classification of a checking account where the parties had orally stipulated at trial to a marital component. The trial court ignored that stipulation and classified the entire account as separate.

Again, the appellate court held this was error. Even mid-trial stipulations—if clear—are binding and must be enforced.

4. Proper Handling of Modified Stipulations

In contrast, the court affirmed the trial court’s handling of the marital residence value. Unlike the townhome, the husband effectively sought to modify the stipulation by introducing updated appraisal, and the trial court conducted a hearing and allowed the modification.

The key distinction: a stipulation may be modified if the court treats the request as a motion to set it aside and rules on it. That procedural step saved the trial court’s ruling on valuation.

5. Burden of Proof Matters—Especially for Investment Gains

Finally, the Court of Appeals addressed the classification of gains in premarital investment accounts. The trial court placed the burden on the wife to prove the gains were marital. This was reversible error.

The correct rule:

• Gains during marriage are presumed marital once shown to have accrued during the marriage
• The burden then shifts to the owning spouse to prove the gains were passive (and thus separate)

Because the trial court misallocated this burden, the case was remanded.

Conclusion

Biddle v. Biddle is a significant reminder that procedure and structure matter as much as substance in equitable distribution cases. The decision underscores:

• The binding nature of pretrial stipulations
• The strict sequencing of classification, valuation, and distribution
• The importance of properly allocating burdens of proof

For practitioners, the lesson is clear: carefully draft and review stipulations—and be prepared to formally move to modify them if circumstances change. Trial courts, in turn, must resist the temptation to “fix” perceived inequities outside the proper analytical framework.

Guy Vitetta, Charleston SC