Leonard v. Leonard

Defendant appeals the trial court’s award of virtually all the marital property to plaintiff upon their divorce. Defendant also asserts that the property disposition award was based, at least in part, on defendant’s admitted criminal conduct of lewd and lascivious acts on plaintiff’s minor child by a prior marriage, and thus, constituted an additional punishment for this crime in violation of his constitutional right against double jeopardy. We affirm.

Neither party requested findings of fact, and the trial court made no findings. Failure to make findings of fact does not preclude our review…