After all, that's one of the main reasons for "bifurcated" divorce and equitable distribution, isn't it?
Death abates a divorce suit by making it moot, but "bifurcating" a divorce case makes the division of property "in essence, a distinct case." Code § 20-107.3 says a court shall divide property "upon decreeing a divorce." The divorce happened while the man was alive, so the divorce still existed after he died and the trial court should have divided the property "upon" it. The Court of Appeals reversed the trial court that had dismissed the case for lack of jurisdiction due to death.
Brown v. Brown, 69 Va. App. 462 (2018)
"However, when a court bifurcates a divorce proceeding, the equitable distribution of marital property is no longer ancillary to the final divorce decree, but rather becomes, in essence, a distinct case. Friedman, 68 Va. App. at 539-40, 810 S.E.2d at 917. Although the status of the marriage has been resolved, the determination of the former spouses’ rights and interests in the marital property remains before the court. Virginia courts have long recognized that adjudication of property rights and interests does not abate with the death of a party. See Squire v. Va. Hous. Dev. Auth., 287 Va. 507, 511, 758 S.E.2d 55, 57 (2014) (considering the merits of quiet title action after administrator of plaintiff’s estate was substituted for plaintiff); Smith’s Ex’x v. Profitt’s Adm’r, 82 Va. 832, 851, 1 S.E. 67, 80 (1887) (considering the merits of a claim of beneficial interest giving rise to "an implied or constructive trust ... to the extent of his interest" after administrators were substituted for two deceased parties); Hinton v. Bland’s Adm’r, 81 Va. 588, 594 (1886) (noting an administrator of deceased was an indispensable party in a partition action where the court was required to "adjust all the equitable rights of the parties interested in the estate")."