Justen Ryan Link v. Kara Koch

── Justen Ryan Link v. Kara Koch ── Court: Court of Appeals of Kentucky Date: May 08, 2026 Author: Cetrulo Category: General RENDERED: MAY 8, 2026; 10:00 A.M. NOT TO BE PUBLISHED Commonwealth of Kentucky Court of Appeals NO. 2025-CA-0863-MR JUSTEN LINK APPELLANT APPEAL FROM JEFFERSON FAMILY COURT v. HONORABLE LAURA P. RUSSELL, JUDGE ACTION NO. 24-CI-500927 KARA KOCH APPELLEE OPINION AFFIRMING ** ** ** ** ** BEFORE: CALDWELL, CETRULO, AND EASTON, JUDGES. CETRULO, JUDGE: Justen Link (“Justen”) appeals the May 2025 Jefferson Family Court order dissolving his marriage and determining the value increase of his real property was divisible marital property. Finding no reversible error and due to Justen’s failure to meet his burden, we affirm the family court. In November 2018, Justen and Kara Koch (“Kara”) were married. Sixteen months prior to the marriage, Justen had purchased a home located on Rawlings Street in Louisville (“Rawlings Street Property”). The record is unclear as to how long and/or if Kara lived at that address with Justen, or the exact date of their separation. In March 2024, Justen and Kara, both pro se, completed and signed a “Self-Help Form 1A Petition for Dissolution of Marriage” together. This jointly completed form stated the couple had no children under the age of 18 and listed the date of separation as December 2023. Both Justen and Kara listed employment at UPS and neither party requested maintenance. Both parties also signed a “Self- Help Form 4A Marital Settlement Agreement.” This agreement stated they had no nonmarital or marital property to be divided, and that they had already allocated all their personal property.1 In June 2024, Justen and Kara, both pro se, appeared at a case management conference. The family court advised both parties that the forms they had submitted were incomplete and needed to be fully completed before the court could proceed. The court also encouraged the parties to retain legal representation because, in part, the Rawlings Street Property might be partially marital, and a quitclaim deed could be necessary for clear title. 1 The family court did not consider this proposed agreement, finding it unconscionable as it did not accurately reflect the assets of the parties. -2-  In July 2024, Kara, through legal counsel, filed a disclosure form stating the parties separated in May 2024, and listed the fair market value of the Rawlings Street Property as $280,000. She indicated she had no information as to the amount of Justen’s mortgage on that property. Justen, through legal counsel, completed his own disclosure form also stating the parties separated in May 2024. He indicated the Rawlings Street Property was nonmarital, with a fair market value of $192,280, a mortgage of $137,464, with $54,816 in equity. At a January 2025 hearing, Kara was no longer represented by counsel, but Justen still retained legal counsel. Again, Justen presented testimony that the Rawlings Street Property was purchased before the marriage, but otherwise neither party presented proof as to value, debt, or equity of the property. The family court continued the hearing, and again instructed the parties to submit complete and updated disclosure statements. In March 2025, Justen submitted another disclosure statement. This statement listed the date of separation as February 2019, three months after the marriage. He again listed the Rawlings Street Property as having a fair market value of $192,280, but this time reported a mortgage of $114,390, with $77,890 in equity. Kara’s updated disclosure