The New Jersey divorce judge erred by declining to consider the claim of a verbal agreement between the parties, pertaining to their jointly owned dog. It was error to disregard the claimed agreement, merely on the basis that a pet is personal property. Agreements about jointly held property are material in actions concerning its division. They may be specifically enforced. Thus, the case is remanded for further proceedings on the existence of an oral agreement about ownership and possession of the dog and the propriety of specific performance. Houseman v. Dare, N.J. Super. (App. Div. 2009); New Jersey App. Div., March 5, 2009