PROPERTY DIVISION – VALUATION – APPEALS – UPDATE ON REMAND. In an unpublished opinion in Harris v. Harris, 20 VLW 1155 (2/21/06), the Court of Appeals held that it was reversible error for a trial court to refuse to revise the valuation of jointly-owned real estate when the case was back on remand after appeal. Using the valuation proved at the original trial date was an abuse of discretion, since that valuation was over three years old, and all of that time the asset had been in the hands of one of the parties, in a greatly raising market.