From 17fb18ca1332d4282ee26b746229c036a387dd6b Mon Sep 17 00:00:00 2001 From: drjones Date: Tue, 6 Oct 2026 23:43:44 -0700 Subject: [PATCH] Snapshot: full project state --- .case-verify/cs_fetch.py | 29 + .case-verify/harvest2.py | 63 + .case-verify/harvest3.py | 64 + .case-verify/harvest_snippets.py | 107 + .case-verify/leagle/check_snaps.py | 46 + .case-verify/leagle/leagle_urls.json | 113 + .case-verify/leagle/snapshots.json | 20 + .case-verify/leagle/wa1997.zip | 133 + .case-verify/leagle_search.py | 75 + .case-verify/meta.json | 73 + .case-verify/snippets/harvest1.json | 257 + .case-verify/snippets/harvest2.json | 288 + .case-verify/snippets/harvest3.json | 72 + .gitignore | 17 + .research/brewer.html | 87 + .research/brewer.txt | 1 + .research/brown.html | 157 + .research/brown.txt | 1 + .research/bulicek.html | 103 + .research/bulicek.txt | 1 + .research/cl_ids.json | 155 + .research/dewberry.html | 20 + .research/dewberry.txt | 1 + .research/fleege.html | 21 + .research/fleege.txt | 1 + .research/friedlander.html | 182 + .research/friedlander.txt | 1 + .research/hall.html | 176 + .research/hall.txt | 1 + .research/hallapproved_wa_ids.json | 87881 +++++++++++++++++++++++++ .research/index_map.json | 34 + .research/konzen.html | 21 + .research/konzen.txt | 1 + .research/kraft.html | 160 + .research/kraft.txt | 1 + .research/olivares.txt | 1 + .research/olivares_studicata.txt | 1 + .research/olivares_vlex.txt | 1 + .research/pennington.html | 21 + .research/pennington.txt | 1 + .research/rockwell2007.html | 353 + .research/rockwell2007.txt | 1 + .research/rockwell2007_at.html | 151 + .research/rockwell2007_findlaw.html | 3 + .research/rockwell2007_vlex.txt | 1 + .research/rockwell2010.html | 21 + .research/rockwell2010.txt | 1 + .research/sedlock.html | 1 + .research/washburn.html | 25 + .research/washburn.txt | 1 + .research/white.txt | 1 + .research/white_at.html | 151 + .research/white_findlaw.html | 3 + .research/white_vlex.txt | 1 + .research/zahm.html | 21 + .research/zahm.txt | 1 + .research/zips/1978.zip | 133 + .research/zips/1979.zip | 133 + .research/zips/1993.zip | 133 + .research/zips/1995.zip | 133 + .research/zips/2001.zip | 133 + .research/zips/2007.zip | 133 + README.md | 13 + adoption.md | 102 + child-support.md | 75 + committed-relationships.md | 94 + custody-parenting.md | 99 + divorce-case-law-characterization.md | 158 + divorce-case-law-division.md | 143 + divorce-case-law-maintenance.md | 142 + divorce-dissolution.md | 144 + guardianship.md | 97 + mediation-adr.md | 109 + modification-enforcement.md | 98 + overview-intake.md | 123 + parentage.md | 95 + property-debt.md | 117 + protection-orders.md | 122 + spousal-maintenance.md | 98 + 79 files changed, 93751 insertions(+) create mode 100644 .case-verify/cs_fetch.py create mode 100644 .case-verify/harvest2.py create mode 100644 .case-verify/harvest3.py create mode 100644 .case-verify/harvest_snippets.py create mode 100644 .case-verify/leagle/check_snaps.py create mode 100644 .case-verify/leagle/leagle_urls.json create mode 100644 .case-verify/leagle/snapshots.json create mode 100644 .case-verify/leagle/wa1997.zip create mode 100644 .case-verify/leagle_search.py create mode 100644 .case-verify/meta.json create mode 100644 .case-verify/snippets/harvest1.json create mode 100644 .case-verify/snippets/harvest2.json create mode 100644 .case-verify/snippets/harvest3.json create mode 100644 .gitignore create mode 100644 .research/brewer.html create mode 100644 .research/brewer.txt create mode 100644 .research/brown.html create mode 100644 .research/brown.txt create mode 100644 .research/bulicek.html create mode 100644 .research/bulicek.txt create mode 100644 .research/cl_ids.json create mode 100644 .research/dewberry.html create mode 100644 .research/dewberry.txt create mode 100644 .research/fleege.html create mode 100644 .research/fleege.txt create mode 100644 .research/friedlander.html create mode 100644 .research/friedlander.txt create mode 100644 .research/hall.html create mode 100644 .research/hall.txt create mode 100644 .research/hallapproved_wa_ids.json create mode 100644 .research/index_map.json create mode 100644 .research/konzen.html create mode 100644 .research/konzen.txt create mode 100644 .research/kraft.html create mode 100644 .research/kraft.txt create mode 100644 .research/olivares.txt create mode 100644 .research/olivares_studicata.txt create mode 100644 .research/olivares_vlex.txt create mode 100644 .research/pennington.html create mode 100644 .research/pennington.txt create mode 100644 .research/rockwell2007.html create mode 100644 .research/rockwell2007.txt create mode 100644 .research/rockwell2007_at.html create mode 100644 .research/rockwell2007_findlaw.html create mode 100644 .research/rockwell2007_vlex.txt create mode 100644 .research/rockwell2010.html create mode 100644 .research/rockwell2010.txt create mode 100644 .research/sedlock.html create mode 100644 .research/washburn.html create mode 100644 .research/washburn.txt create mode 100644 .research/white.txt create mode 100644 .research/white_at.html create mode 100644 .research/white_findlaw.html create mode 100644 .research/white_vlex.txt create mode 100644 .research/zahm.html create mode 100644 .research/zahm.txt create mode 100644 .research/zips/1978.zip create mode 100644 .research/zips/1979.zip create mode 100644 .research/zips/1993.zip create mode 100644 .research/zips/1995.zip create mode 100644 .research/zips/2001.zip create mode 100644 .research/zips/2007.zip create mode 100644 README.md create mode 100644 adoption.md create mode 100644 child-support.md create mode 100644 committed-relationships.md create mode 100644 custody-parenting.md create mode 100644 divorce-case-law-characterization.md create mode 100644 divorce-case-law-division.md create mode 100644 divorce-case-law-maintenance.md create mode 100644 divorce-dissolution.md create mode 100644 guardianship.md create mode 100644 mediation-adr.md create mode 100644 modification-enforcement.md create mode 100644 overview-intake.md create mode 100644 parentage.md create mode 100644 property-debt.md create mode 100644 protection-orders.md create mode 100644 spousal-maintenance.md diff --git a/.case-verify/cs_fetch.py b/.case-verify/cs_fetch.py new file mode 100644 index 0000000..4e41d94 --- /dev/null +++ b/.case-verify/cs_fetch.py @@ -0,0 +1,29 @@ +import cloudscraper, re, os, sys + +OUT = "/Users/drjones/astraea-books/.case-verify" +os.makedirs(OUT, exist_ok=True) + +def scrape(url, fname): + s = cloudscraper.create_scraper(browser={'browser':'chrome','platform':'darwin','mobile':False}) + try: + r = s.get(url, timeout=90) + print(fname, "status:", r.status_code, "len:", len(r.text)) + if r.status_code == 200 and len(r.text) > 20000: + open(os.path.join(OUT, fname + ".html"), "w").write(r.text) + html = r.text + print(" has 'Wash.2d':", "Wash.2d" in html, "| has 'opinion':", "opinion" in html.lower()) + return html + else: + print(" short/failed, head:", r.text[:200].replace("\n"," ")) + return None + except Exception as e: + print(fname, "ERR:", e) + return None + +url = sys.argv[1] if len(sys.argv) > 1 else "https://law.justia.com/cases/washington/supreme-court/1997/64471-3-1.html" +fname = sys.argv[2] if len(sys.argv) > 2 else "justia_little" +h = scrape(url, fname) +if h: + for marker in ['id="opinion"', 'class="page-content', 'justia-citation', '", i) diff --git a/.case-verify/harvest2.py b/.case-verify/harvest2.py new file mode 100644 index 0000000..5172747 --- /dev/null +++ b/.case-verify/harvest2.py @@ -0,0 +1,63 @@ +import json, urllib.request, urllib.parse, time, os + +UA = {"User-Agent": "Mozilla/5.0 (Macintosh; Intel Mac OS X 10_15_7) AppleWebKit/537.36"} +OUT = "/Users/drjones/astraea-books/.case-verify/snippets" + +def search(q, court=None, after=None, before=None, n=6): + qq = urllib.parse.quote(q) + url = f"https://www.courtlistener.com/api/rest/v4/search/?q={qq}&type=o&format=json" + if court: url += f"&court={court}" + if after: url += f"&filed_after={after}" + if before: url += f"&filed_before={before}" + for i in range(4): + try: + req = urllib.request.Request(url, headers=UA) + with urllib.request.urlopen(req, timeout=40) as r: + return json.loads(r.read()) + except Exception as e: + if i == 3: return {"error": str(e)} + time.sleep(5 + i * 5) + +# (name, court, after, before, queries) +CASES = { + "Littlefield": ("wash", "1997-01-01", "1997-12-31", ["commingled trace separate community presumption", '"commingling" separate property trace', 'reverse commingling Littlefield']), + "Kovacs": ("wash", "1993-01-01", "1993-12-31", ["transmutation joint tenancy separate property", 'donative intent transmutation', 'character acquisition transmutation']), + "Chumbley": ("wash", "2003-01-01", "2003-12-31", ['commingling appreciation separate contribution', 'separate funds community funds acquisition', 'tracing formula equity']), + "Short": ("wash", "1995-01-01", "1995-12-31", ['transmutation separate property', 'commingling characterization', 'presumption community gift']), + "Borghi": ("wash", "2009-01-01", "2009-12-31", ['joint tenancy characterization intent', 'commingling separate funds', 'presumption community property title']), + "Elam": ("wash", "1982-01-01", "1982-12-31", ['gift presumption community property', 'clear and convincing separate property', 'characterization acquisition']), + "Konzen": ("wash", "1985-01-01", "1985-12-31", ['characterization date of acquisition', 'separate property commingling', 'transmutation agreement']), + "Mueller": ("washctapp", "2007-01-01", "2007-12-31", ['commingled trace separate funds', 'clear and satisfactory evidence tracing', 'Littlefield commingling account']), + "Glorfield": ("washctapp", "1980-01-01", "1980-12-31", ['transmutation separate property community', 'intent transmutation', 'gift community presumption']), + "PearsonMaines": ("washctapp", "1993-01-01", "1993-12-31", ['transmutation separate property intent', 'joint tenancy presumption gift', 'commingling characterization']), + "Olivares": ("washctapp", "1993-01-01", "1993-12-31", ['transmutation separate property', 'joint tenancy gift community', 'intent transmutation evidence']), + "Sedlock": ("washctapp", "1993-01-01", "1993-12-31", ['transmutation agreement separate community', 'joint title transmutation', 'characterization intent']), + "Hadley": ("wash", "1977-01-01", "1977-12-31", ['separate property division award', 'court may not award separate property', 'just and equitable division']), + "Schwarz": ("washctapp", "2016-01-01", "2016-12-31", ['equitable lien community funds separate property', 'commingling tracing accounts', 'reimbursement separate property mortgage']), + "Kraft": ("wash", "1992-01-01", "1992-12-31", ['separate property division dissolution', 'exceptional circumstances separate property', 'property characterization acquisition']), + "Berol": ("wash", "1950-01-01", "1950-12-31", ['deed presumption community property', 'transmutation deed separate', 'gift deed community']), +} + +allout = {} +for name, (court, after, before, queries) in CASES.items(): + snips = [] + for q in queries: + d = search(q, court, after, before) + if "error" in d: + snips.append({"q": q, "err": d["error"]}); continue + for res in d.get("results", []): + sn = res.get("opinions", [{}])[0].get("snippet", "") + if len(sn) > 200: + snips.append({"q": q, "case": res.get("caseName"), "date": res.get("dateFiled"), + "cit": res.get("citation", [])[:2], "snip": sn}) + break + time.sleep(2) + allout[name] = snips + print(f"=== {name}: {len(snips)} snippets") + for s in snips: + if "err" in s: print(" ERR", s["err"]); continue + print(" Q:", s["q"], "|", s["case"], "|", s["date"]) + time.sleep(2) + +json.dump(allout, open(f"{OUT}/harvest2.json", "w"), indent=1) +print("saved harvest2.json") diff --git a/.case-verify/harvest3.py b/.case-verify/harvest3.py new file mode 100644 index 0000000..52abb81 --- /dev/null +++ b/.case-verify/harvest3.py @@ -0,0 +1,64 @@ +import json, urllib.request, urllib.parse, time, os + +UA = {"User-Agent": "Mozilla/5.0 (Macintosh; Intel Mac OS X 10_15_7) AppleWebKit/537.36"} +OUT = "/Users/drjones/astraea-books/.case-verify/snippets" + +def search(q, court=None, after=None, before=None, n=6): + qq = urllib.parse.quote(q) + url = f"https://www.courtlistener.com/api/rest/v4/search/?q={qq}&type=o&format=json" + if court: url += f"&court={court}" + if after: url += f"&filed_after={after}" + if before: url += f"&filed_before={before}" + for i in range(4): + try: + req = urllib.request.Request(url, headers=UA) + with urllib.request.urlopen(req, timeout=40) as r: + return json.loads(r.read()) + except Exception as e: + if i == 3: return {"error": str(e)} + time.sleep(5 + i * 5) + +# (name, court, after, before, queries, target_substring) +CASES = { + "Littlefield_own": ("wash", "1997-01-01", "1997-12-31", ['"burden of proving" commingling', '"trace" "separate property" commingled', '"clear and satisfactory" evidence'], "littlefield"), + "Littlefield_cited": ("washctapp", "2010-01-01", "2026-12-31", ['"Littlefield" commingling tracing separate'], "littlefield"), + "Kovacs_own": ("wash", "1993-01-01", "1993-12-31", ['transmutation "joint tenancy"', '"clear and convincing" transmutation', '"source of funds" acquisition'], "kovacs"), + "Kovacs_cited": ("wash", "2000-01-01", "2026-12-31", ['"Kovacs" transmutation'], "kovacs"), + "Short_own": ("wash", "1995-01-01", "1995-12-31", ['"transmutation" Short 61176', '"separate property" commingled account'], "short"), + "Short_cited": ("wash", "2000-01-01", "2026-12-31", ['"In re Marriage of Short"'], "short"), + "Elam_own": ("wash", "1982-01-01", "1982-12-31", ['"gift" "community property" presumption acquisition', '"clear and convincing evidence" rebut'], "elam"), + "Konzen_own": ("wash", "1985-01-01", "1985-12-31", ['"date of acquisition" separate community'], "konzen"), + "Mueller_own": ("washctapp", "2007-01-01", "2007-12-31", ['commingling "reasonable certainty"', '"clear and satisfactory" trace separate'], "mueller"), + "Glorfield_own": ("washctapp", "1980-01-01", "1980-12-31", ['transmutation community intent'], "glorfield"), + "PearsonM_own": ("washctapp", "1993-01-01", "1993-12-31", ['"transmutation" separate property community'], "pearson-maines"), + "Olivares_own": ("washctapp", "1993-01-01", "1993-12-31", ['"transmutation"', '"joint tenancy" separate'], "olivares"), + "Sedlock_own": ("washctapp", "1993-01-01", "1993-12-31", ['"transmutation"', '"changed its character"'], "sedlock"), + "Hadley_cited": ("wash", "1990-01-01", "2026-12-31", ['"Hadley" separate property division'], "hadley"), + "Kraft_cited": ("washctapp", "2010-01-01", "2026-12-31", ['"Kraft" separate property "economic circumstances"'], "kraft"), + "Berol_own": ("wash", "1950-01-01", "1950-12-31", ['"presumption" community deed Berol'], "berol"), +} + +allout = {} +for name, (court, after, before, queries, target) in CASES.items(): + snips = [] + for q in queries: + d = search(q, court, after, before) + if "error" in d: + snips.append({"q": q, "err": d["error"]}); continue + for res in d.get("results", []): + cn = (res.get("caseName") or "").lower() + sn = res.get("opinions", [{}])[0].get("snippet", "") + if len(sn) > 200: + snips.append({"q": q, "case": res.get("caseName"), "date": res.get("dateFiled"), + "cit": res.get("citation", [])[:2], "snip": sn}) + break + time.sleep(2) + allout[name] = snips + print(f"=== {name}: {len(snips)}") + for s in snips: + if "err" in s: print(" ERR", s["err"]); continue + print(" Q:", s["q"], "|", s["case"], "|", s["date"]) + time.sleep(2) + +json.dump(allout, open(f"{OUT}/harvest3.json", "w"), indent=1) +print("saved harvest3.json") diff --git a/.case-verify/harvest_snippets.py b/.case-verify/harvest_snippets.py new file mode 100644 index 0000000..ebc3833 --- /dev/null +++ b/.case-verify/harvest_snippets.py @@ -0,0 +1,107 @@ +import json, urllib.request, urllib.parse, time, os + +UA = {"User-Agent": "Mozilla/5.0 (Macintosh; Intel Mac OS X 10_15_7) AppleWebKit/537.36"} +OUT = "/Users/drjones/astraea-books/.case-verify/snippets" +os.makedirs(OUT, exist_ok=True) + +def search(q, court=None, n=4): + qq = urllib.parse.quote(q) + url = f"https://www.courtlistener.com/api/rest/v4/search/?q={qq}&type=o&format=json" + if court: + url += f"&court={court}" + for i in range(4): + try: + req = urllib.request.Request(url, headers=UA) + with urllib.request.urlopen(req, timeout=40) as r: + return json.loads(r.read()) + except Exception as e: + if i == 3: + return {"error": str(e)} + time.sleep(5 + i * 5) + +CASES = { + "Littlefield": ("wash", ["Littlefield commingle trace separate property", + "Littlefield \"clear and satisfactory\" evidence trace", + "Littlefield reverse commingling burden"]), + "Kovacs": ("wash", ["Kovacs marriage transmutation separate property", + "Kovacs marriage characterization acquisition", + "Kovacs marriage clear and convincing community"]), + "Chumbley": ("wash", ["Chumbley marriage separate contribution appreciation", + "Chumbley marriage tracing formula community interest", + "Chumbley marriage commingling acquisition"]), + "Short": ("wash", ["Short marriage transmutation separate property", + "Short marriage characterization 61176-9", + "Short marriage community presumption tracing"]), + "Borghi": ("wash", ["Borghi estate community property presumption", + "Borghi Gilroy separate property tracing", + "Borghi estate clear and convincing"]), + "Elam": ("wash", ["Elam marriage characterization acquisition gift", + "Elam marriage transmutation separate property", + "Elam marriage presumption community burden"]), + "Konzen": ("wash", ["Konzen marriage characterization acquisition date", + "Konzen marriage separate community funds", + "Konzen marriage transmutation"]), + "Skarbek": ("washctapp", ["Skarbek marriage transmutation inheritance", + "Skarbek marriage separate property intent", + "Skarbek marriage commingling community"]), + "PearsonMaines": ("washctapp", ["Pearson-Maines transmutation intent", + "Pearson-Maines separate property joint tenancy", + "Pearson-Maines marriage gift presumption"]), + "Olivares": ("washctapp", ["Olivares transmutation separate property", + "Olivares marriage joint tenancy intent", + "Olivares marriage characterization"]), + "Sedlock": ("washctapp", ["Sedlock transmutation community property", + "Sedlock marriage separate property agreement", + "Sedlock marriage characterization"]), + "Glorfield": ("washctapp", ["Glorfield transmutation separate property", + "Glorfield marriage community intent", + "Glorfield marriage characterization"]), + "Hadley": ("wash", ["Hadley marriage separate property division", + "Hadley marriage 88 Wash.2d 649", + "Hadley marriage just and equitable"]), + "Schwarz": ("washctapp", ["Schwarz v. Schwarz separate property mortgage community", + "Schwarz marriage commingling tracing", + "Schwarz marriage reimbursement community funds"]), + "Kraft": ("wash", ["Kraft marriage separate property division dissolution", + "Kraft marriage 119 Wash.2d 438", + "Kraft marriage exceptional circumstances"]), + "Berol": ("wash", ["Berol v. Berol transmutation community property", + "Berol separate property deed community", + "Berol v. Berol characterization"]), + "Brewer": ("wash", ["Brewer marriage separate property division", + "Brewer marriage just and equitable property", + "Brewer marriage 137 Wash.2d"]), + "Mueller": ("washctapp", ["Mueller marriage commingling trace separate", + "Mueller marriage \"clear and satisfactory\"", + "Mueller marriage Littlefield tracing"]), +} + +allout = {} +for name, (court, queries) in CASES.items(): + snippets = [] + for q in queries: + d = search(q, court) + if "error" in d: + snippets.append({"q": q, "err": d["error"]}) + continue + for res in d.get("results", []): + cn = (res.get("caseName") or "").lower() + if name.lower().split("maines")[0].split("schwarz")[0].split("berol")[0] not in cn and name.lower() not in cn: + continue + sn = res.get("opinions", [{}])[0].get("snippet", "") + if len(sn) > 200: + snippets.append({"q": q, "case": res.get("caseName"), "date": res.get("dateFiled"), + "cit": res.get("citation", [])[:2], "snip": sn}) + break + time.sleep(2) + allout[name] = snippets + print(f"=== {name}: {len(snippets)} snippets") + for s in snippets[:3]: + if "err" in s: + print(" ERR", s["err"]); continue + print(" Q:", s["q"]) + print(" ", s["case"], "|", s["date"], "|", s["cit"]) + time.sleep(2) + +json.dump(allout, open(f"{OUT}/harvest1.json", "w"), indent=1) +print("saved harvest1.json") diff --git a/.case-verify/leagle/check_snaps.py b/.case-verify/leagle/check_snaps.py new file mode 100644 index 0000000..bc12ad9 --- /dev/null +++ b/.case-verify/leagle/check_snaps.py @@ -0,0 +1,46 @@ +import json, urllib.request, urllib.parse, time + +urls = { + "Littlefield": "https://www.leagle.com/decision/19972302940p2d136212273", + "Kovacs": "https://www.leagle.com/decision/1993916121wn2d7951867", + "Chumbley": "https://www.leagle.com/decision/200320374p3d1291201", + "Short": "https://www.leagle.com/decision/1995990125wn2d8651942", + "Borghi": "https://www.leagle.com/decision/inwaco20091105c91", + "Elam": "https://www.leagle.com/decision/198290897wn2d8111823", + "Konzen": "https://www.leagle.com/decision/1985573103wn2d4701535", + "Skarbek": "https://www.leagle.com/decision/20001444997p2d44711431", + "PearsonMaines": "https://www.leagle.com/decision/199393070wnapp8601840", + "Olivares": "https://www.leagle.com/decision/199339369wnapp3241358", + "Sedlock": "https://www.leagle.com/decision/199355369wnapp4841494", + "Glorfield": "https://www.leagle.com/decision/198038527wnapp3581343", + "Hadley": "https://www.leagle.com/decision/197773788wn2d6491672", + "Mueller": "https://www.leagle.com/decision/2007735167p3d5681730", + "Schwarz": "https://www.leagle.com/decision/inwaco20160115u75", + "Kraft": "https://www.leagle.com/decision/1992557119wn2d4381530", + "Berol": "https://www.leagle.com/decision/195041737wn2d3801367", + "Brewer": "https://www.leagle.com/decision/19991078976p2d10211078", +} + +def get(url, tries=2): + for i in range(tries): + try: + req = urllib.request.Request(url, headers={"User-Agent": "Mozilla/5.0"}) + with urllib.request.urlopen(req, timeout=40) as r: + return json.loads(r.read()) + except Exception as e: + if i == tries-1: + return {"error": str(e)} + time.sleep(5) + +out = {} +for name, u in urls.items(): + d = get("https://archive.org/wayback/available?url=" + urllib.parse.quote(u, safe="")) + snap = None + if "archived_snapshots" in d and d["archived_snapshots"].get("closest", {}).get("available"): + snap = d["archived_snapshots"]["closest"]["url"] + out[name] = snap + print(name, "=>", snap or "NO SNAPSHOT") + time.sleep(2.5) + +json.dump(out, open("/Users/drjones/astraea-books/.case-verify/leagle/snapshots.json", "w"), indent=1) +print("saved snapshots.json") diff --git a/.case-verify/leagle/leagle_urls.json b/.case-verify/leagle/leagle_urls.json new file mode 100644 index 0000000..74af114 --- /dev/null +++ b/.case-verify/leagle/leagle_urls.json @@ -0,0 +1,113 @@ +{ + "Littlefield": { + "id": "19972302940p2d136212273", + "name": "IN RE MARRIAGE OF LITTLEFIELD", + "date": "August 7, 1997", + "info": "Supreme Court of Washington, En Banc. No. 64471-3." + }, + "Kovacs": { + "id": "1993916121wn2d7951867", + "name": "MARRIAGE OF KOVACS", + "date": "July 8, 1993", + "info": "The Supreme Court of Washington, En Banc. No. 60035-0." + }, + "Chumbley": { + "id": "200320374p3d1291201", + "name": "IN RE MARRIAGE OF CHUMBLEY", + "date": "August 14, 2003", + "info": "Supreme Court of Washington, En Banc. No. 72539-0." + }, + "Short": { + "id": "1995990125wn2d8651942", + "name": "IN RE MARRIAGE OF SHORT", + "date": "May 10, 1995", + "info": "The Supreme Court of Washington, En Banc. No. 61176-9." + }, + "Borghi": null, + "Elam": { + "id": "198290897wn2d8111823", + "name": "IN RE MARRIAGE OF ELAM", + "date": "September 2, 1982", + "info": "The Supreme Court of Washington, En Banc. No. 48219-5." + }, + "Konzen": { + "id": "1985573103wn2d4701535", + "name": "MARRIAGE OF KONZEN", + "date": "January 11, 1985", + "info": "The Supreme Court of Washington, En Banc. No. 50402-4." + }, + "Witte": null, + "Skarbek": { + "id": "20001444997p2d44711431", + "name": "IN RE MARRIAGE OF SKARBEK", + "date": "April 18, 2000", + "info": "Court of Appeals of Washington, Division 3, Panel 3. No. 18013-1-III." + }, + "PearsonMaines": { + "id": "199393070wnapp8601840", + "name": "MATTER OF MARRIAGE OF PEARSON-MAINES", + "date": "August 9, 1993", + "info": "The Court of Appeals of Washington, Division One. No. 29873-9-I." + }, + "Olivares": { + "id": "199339369wnapp3241358", + "name": "MATTER OF MARRIAGE OF OLIVARES", + "date": "April 12, 1993", + "info": "The Court of Appeals of Washington, Division One. No. 28758-3-I." + }, + "Sedlock": { + "id": "199355369wnapp4841494", + "name": "MATTER OF MARRIAGE OF SEDLOCK", + "date": "April 26, 1993", + "info": "The Court of Appeals of Washington, Division One. No. 28848-2-I." + }, + "Glorfield": { + "id": "198038527wnapp3581343", + "name": "IN RE MARRIAGE OF GLORFIELD", + "date": "October 2, 1980", + "info": "The Court of Appeals of Washington, Division Three. No. 3410-1-III." + }, + "Hadley": { + "id": "197773788wn2d6491672", + "name": "IN RE MARRIAGE OF HADLEY", + "date": "June 9, 1977", + "info": "The Supreme Court of Washington, En Banc. No. 44308." + }, + "Mueller": { + "id": "2007735167p3d5681730", + "name": "IN RE MARRIAGE OF MUELLER", + "date": "September 12, 2007", + "info": "Court of Appeals of Washington, Division 1. No. 57592-9-I." + }, + "White": null, + "Schwarz": { + "id": "inwaco20160115u75", + "name": "SCHWARZ v. SCHWARZ", + "date": "January 12, 2016", + "info": "Court of Appeals of Washington, Division 3. No. 32274-2-III." + }, + "Kraft": { + "id": "1992557119wn2d4381530", + "name": "MARRIAGE OF KRAFT", + "date": "July 23, 1992", + "info": "The Supreme Court of Washington, En Banc. No. 58247-5." + }, + "Berol": { + "id": "195041737wn2d3801367", + "name": "BEROL v. BEROL", + "date": "November 16, 1950", + "info": "The Supreme Court of Washington, Department One. No. 31379." + }, + "Brewer": { + "id": "19991078976p2d10211078", + "name": "BREWER v. BREWER", + "date": "May 6, 1999", + "info": "Supreme Court of Washington, En Banc. No. 66577-0." + }, + "Brown": { + "id": "inwaco20260319i73", + "name": "ESTATE OF BROWN v. KING COUNTY", + "date": "March 19, 2026", + "info": "Court of Appeals of Washington, Division 3. No. 40983-0-III." + } +} \ No newline at end of file diff --git a/.case-verify/leagle/snapshots.json b/.case-verify/leagle/snapshots.json new file mode 100644 index 0000000..f85cfa0 --- /dev/null +++ b/.case-verify/leagle/snapshots.json @@ -0,0 +1,20 @@ +{ + "Littlefield": "http://web.archive.org/web/20230327110258/https://www.leagle.com/decision/19972302940p2d136212273", + "Kovacs": "http://web.archive.org/web/20230327110249/https://www.leagle.com/decision/1993916121wn2d7951867", + "Chumbley": null, + "Short": null, + "Borghi": "http://web.archive.org/web/20231002122253/https://www.leagle.com/decision/inwaco20091105c91", + "Elam": null, + "Konzen": null, + "Skarbek": null, + "PearsonMaines": null, + "Olivares": null, + "Sedlock": null, + "Glorfield": null, + "Hadley": null, + "Mueller": null, + "Schwarz": null, + "Kraft": null, + "Berol": null, + "Brewer": null +} \ No newline at end of file diff --git a/.case-verify/leagle/wa1997.zip b/.case-verify/leagle/wa1997.zip new file mode 100644 index 0000000..9e232f0 --- /dev/null +++ b/.case-verify/leagle/wa1997.zip @@ -0,0 +1,133 @@ + + + + + Leagle.com | A leading provider of copies of primary caselaw from all Federal courts and all State higher courts + + + + + + + +
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Leagle, Inc. is a leading provider of copies of primary caselaw from all Federal courts and all State higher courts. Our collection is up to date within 24 hours of release of opinions from the courts and is also complete historically for all time for Federal courts and back to 1950 for state appellate and supreme courts. We add Slip Opinions daily, and Advance Sheets and Bound Volume copies as they become available. Our materials are fully copyrighted by Leagle, Inc.

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+ + diff --git a/.case-verify/leagle_search.py b/.case-verify/leagle_search.py new file mode 100644 index 0000000..ab525fa --- /dev/null +++ b/.case-verify/leagle_search.py @@ -0,0 +1,75 @@ +import re, subprocess, json, time, os + +UA = "Mozilla/5.0 (Macintosh; Intel Mac OS X 10_15_7) AppleWebKit/537.36 (KHTML, like Gecko) Chrome/120.0 Safari/537.36" +CK = "/tmp/lg_c.txt" + +CASES = [ + ("Littlefield", "Littlefield", "64471-3"), + ("Kovacs", "Kovacs", "60035-0"), + ("Chumbley", "Chumbley", "72539-0"), + ("Short", "Short", "61176-9"), + ("Borghi", "Gilroy", "80925-9"), + ("Elam", "Elam", "48219-5"), + ("Konzen", "Konzen", "50402-4"), + ("Witte", "Witte", "29341"), + ("Skarbek", "Skarbek", "18013-1-III"), + ("PearsonMaines", "Pearson-Maines", "29873-9-I"), + ("Olivares", "Olivares", "28758-3-I"), + ("Sedlock", "Sedlock", "28848-2-I"), + ("Glorfield", "Glorfield", "3410-1-III"), + ("Hadley", "Hadley", "44308"), + ("Mueller", "Mueller", "57592-9-I"), + ("White", "White", "23917-5-II"), + ("Schwarz", "Schwarz", "32274-2-III"), + ("Kraft", "Kraft", "58247-5"), + ("Berol", "Berol", "31379"), + ("Brewer", "Brewer", "66577-0"), + ("Brown", "Brown", "49548-3"), +] + +def curl(url, cookie_file=None, write=False, get_params=None): + cmd = ["curl", "-s", "-m", "40", "-H", f"User-Agent: {UA}"] + if cookie_file: + cmd += ["-b", cookie_file, "-c", cookie_file] + if get_params: + cmd += ["-G"] + for k, v in get_params.items(): + cmd += ["--data-urlencode", f"{k}={v}"] + cmd.append(url) + r = subprocess.run(cmd, capture_output=True, text=True, timeout=50) + return r.stdout + +def leagle_search(query): + h = curl("https://www.leagle.com/leaglesearch", cookie_file=CK, + get_params={"casen": query, "crt": "Washington"}) + results = [] + for m in re.finditer(r']*>\s*

([^<]+)\(\s*([^<]+)\s*\)\s*

\s*

(.*?)

', h, re.S): + did, name, date, info = m.group(1), m.group(2).strip(), m.group(3).strip(), m.group(4) + info = re.sub(r'<[^>]+>', ' ', info) + info = re.sub(r'\s+', ' ', info).strip() + results.append({"id": did, "name": name, "date": date, "info": info}) + return results + +# ensure cookies +curl("https://www.leagle.com/search", cookie_file=CK) +time.sleep(1) + +all_res = {} +for key, query, docket in CASES: + rs = leagle_search(query) + picked = None + # prefer docket match + for r in rs: + if docket.replace("-", "") in r["info"].replace("-", "").replace(" ", ""): + picked = r; break + if not picked: + for r in rs: + n = r["name"].lower() + if key.lower() in n and ("marriage" in n or "estate" in n or key.lower() == "berol"): + picked = r; break + all_res[key] = picked + print(key, "=>", (picked["id"], picked["date"], picked["info"][:70]) if picked else f"NOT FOUND ({len(rs)} results)") + time.sleep(3) + +json.dump(all_res, open("/Users/drjones/astraea-books/.case-verify/leagle/leagle_urls.json", "w"), indent=1) +print("saved") diff --git a/.case-verify/meta.json b/.case-verify/meta.json new file mode 100644 index 0000000..f7015d7 --- /dev/null +++ b/.case-verify/meta.json @@ -0,0 +1,73 @@ +{ + "Littlefield": { + "cluster_id": 1172595, + "caseName": "In Re Marriage of Littlefield", + "court": "Washington Supreme Court", + "dateFiled": "1997-08-07", + "citations": [ + "940 P.2d 1362" + ], + "docket": "64471-3", + "snippet": "\n940 P.2d 1362 (1997)\n133 Wash.2d 39\nIn re the MARRIAGE OF Edmund W. LITTLEFIELD, Jr., Respondent, and\nCharissa L.D. Littlefield, Appellant.\nNo. 64471-3.\nSupreme Court of Washington, En Banc.\nArgued January 22, 1997.\nDecided August 7, 1997.\n*1363 Edwards, Sieh, Hathaway, Smith & Goodfriend," + }, + "Kovacs": { + "cluster_id": 1447919, + "caseName": "In Re the Marriage of Kovacs", + "court": "Washington Supreme Court", + "dateFiled": "1993-07-08", + "citations": [ + "854 P.2d 629", + "121 Wash. 2d 795", + "1993 Wash. LEXIS 141" + ], + "docket": "60035-0", + "snippet": "\n121 Wn.2d 795 (1993)\n854 P.2d 629\nIn the Matter of the Marriage of MARCIA JEAN KOVACS, Respondent, and JOHN E. KOVACS, Petitioner.\nNo. 60035-0.\nThe Supreme Court of Washington, En Banc.\nJuly 8, 1993.\nKevin O'Shaughnessy, for petitioner.\nMichael F. Keyes, for respondent.\n*797 ANDERSEN, C" + }, + "Chumbley": { + "cluster_id": 2625397, + "caseName": "In Re Marriage of Chumbley", + "court": "Washington Supreme Court", + "dateFiled": "2003-08-14", + "citations": [ + "74 P.3d 129" + ], + "docket": "72539-0", + "snippet": "\n74 P.3d 129 (2003)\n150 Wash.2d 1\nIn re the MARRIAGE OF Gerald Steven CHUMBLEY, Respondent, and\nMary Patricia Beckmann, Petitioner.\nNo. 72539-0.\nSupreme Court of Washington, En Banc.\nArgued February 25, 2003.\nDecided August 14, 2003.\n*130 Wiggins Law Office, Charles Wiggins, Kenneth Masters, Ba" + }, + "Short": { + "cluster_id": 2617598, + "caseName": "In Re the Marriage of Short", + "court": "Washington Supreme Court", + "dateFiled": "1995-05-10", + "citations": [ + "890 P.2d 12", + "125 Wash. 2d 865" + ], + "docket": "61176-9", + "snippet": "\n125 Wn.2d 865 (1995)\n890 P.2d 12\nIn the Matter of the Marriage of ROBERT T. SHORT, Petitioner, and PATRICIA A. SHORT, Respondent.\nNo. 61176-9.\nThe Supreme Court of Washington, En Banc.\nFebruary 23, 1995.\nAs amended by order May 10, 1995.\nMaltman, Reed, North, Ahrens & Malnati, P.S., by Douglass A. North; Hollis HolmanIn re the Marriage of Brewer, 137 Wash. 2d 756 (Wash. 1999) | HallApproved.com
Hall Approved +Free Access to American Case Law
Washington Supreme Court, 1999 +

In re the Marriage of Brewer

In re the Marriage of Brewer
Washington Supreme Court · Decided May 6, 1999 · Guy, Smith
137 Wash. 2d 756; 976 P.2d 102; 1999 Wash. LEXIS 284

In re the Marriage of Brewer

Concurring Opinion

Guy, C.J.

(concurring) — I agree with the majority that the rule enunciated in In re Marriage of Brown, 100 Wn.2d 729, 675 P.2d 1207 (1984), applies to wage-replacement disability insurance benefits. I write separately because (1) I would specifically overrule Chase v. Chase, 74 Wn.2d 253, 444 P.2d 145 (1968), and (2) I would clarify that post-dissolution wage-replacement benefits are not “assets” that are before the trial court in a dissolution proceeding.

Courts and commentators alike have recognized the inconsistency in Washington’s case law in this area. See, e.g., In re Marriage of Huteson, 27 Wn. App. 539, 542-43, 619 P.2d 991 (1980) (questioning both the logic and wisdom of Chase, and holding “To treat . . . disability payments as a community asset would unfairly and permanently burden those future earnings to the same extent as would an award of permanent alimony.”); In re Marriage of Brewer, 89 Wn. App. 425, 430, 949 P.2d 404 (1998) (noting that, in light of criticism and newer case law, the continuing viability of the Chase rule “is questionable”)69; 1 Washington State Bar Ass’n, Family Law Deskbook § 38.3(5), at SU-38-2 (Supp. 1996) (“The status of Washington law as to when disability benefits to be paid after entry of a decree constitute ‘property’ subject to distribution by the trial court in a dissolution action is ‘not all together clear.’ In fact, some Washington cases classify disability benefits as property subject to distribution, others classify them as income not subject to distribution, and still others classify disability benefits as part property and part income.”); Harry M. Cross, The Community Property Law in Washington (Revised 1985), 61 Wash. L. Rev. 13, 64 (1986) (“the proper treatment of disability insurance or pension payments . . . should be reconsidered in light of the decision in Brown”); 20 Kenneth W Weber, Washington Eractice: Family and Community *773Property Law § 32.17, at 190-91 (1997) (“retirement benefits are generally considered deferred compensation for past services, and . . . are considered an asset and divisible as such. ... By contrast, disability benefits that are in the nature of compensation for lost future wages (sometimes called future earnings replacement) are generally not an asset for distribution upon dissolution, though contrary results have been reached in a few cases.” (footnote omitted).

The authors of the State Bar Association Community Property Deskbook state:

Disability payments normally represent compensation for diminished earning capacity, replacing lost wages. Thus viewed, the payments are not a form of deferred compensation, rather they are a form of current compensation.
The California courts have held that disability payments received during marriage will be considered community property. Payments to be received after dissolution of marriage will be considered separate property.
This result should be reached in Washington under the reasoning of In re Marriage of Brown .... Earlier cases, however, reached a contrary result.

Washington State Bar Ass’n, Community Property Deskbook § 3.24, at 3-31 to 3-32 (2d ed. 1989) (citation omitted). See also In re Marriage of Nuss, 65 Wn. App. 334, 343, 828 P.2d 627 (1992) (disability benefits which are in the nature of compensation for lost future wages are not an asset for distribution upon dissolution; by contrast, disability benefits which are in the nature of deferred compensation or retirement pay are community property); In re Marriage of Anglin, 52 Wn. App. 317, 324, 759 P.2d 1224 (1988) (disability benefits characterized as repayment for lost future wages were not a marital asset to be characterized and distributed by the court).

In my view, we should clarify the law by overruling Chase and hold: Disability payments which are in the nature of earnings replacement are treated the same as the earnings *774of a healthy spouse. Therefore, when the parties are married and not separated, the replacement earnings would be community property; assets purchased with or generated by community funds are assets belonging to the community. RCW 26.16.030. When the parties are separated, their earnings—whether a result of wage replacement disability benefits or of personal labor—are separate property. RCW 26.16.140. Future, postdissolution earnings, whether received from employment, business ventures, investment, or disability benefits, are not “assets” which are before the court for disposition in a dissolution action. See Brown, 100 Wn.2d at 738; In re Marriage of Hall, 103 Wn.2d 236, 247, 692 P.2d 175 (1984) (future earning capacity is not a marital asset). However, the trial court may consider such earnings when determining what constitutes a fair and equitable distribution of the assets and debts which are before the court. RCW 26.09.080 (economic circumstances of each spouse is a relevant factor in making a property disposition); Hall, 103 Wn.2d at 247; In re Marriage of Leland, 69 Wn. App. 57, 72, 847 P.2d 518 (1993). The trial court also may consider such earnings when determining the propriety and amount of any maintenance award. RCW 26.09.090.

Durham, Madsen, and Alexander, JJ., concur with Guy, C.J.

Because of the similarity of the facts in this case and those in Chase v. Chase, 74 Wn.2d 253, 444 P.2d 145 (1968), I cannot fault the Court of Appeals for feeling—reluctantly—bound to follow the rule articulated in Chase.

Opinion of the Court

Smith, J.

Petitioner Michael A. Brewer seeks review of a decision of the Court of Appeals, Division Two, which reversed and remanded to the Clark County Superior Court a ruling characterizing monthly payments to a permanently disabled spouse under a private disability insurance policy after dissolution of a marriage as separate property and not community property. We granted review. We affirm the Court of Appeals in part and reverse it in part.

QUESTION PRESENTED

The question presented in this case is whether monthly payments to a permanently disabled spouse under a private disability insurance policy after dissolution of a marriage constitutes separate property and not community property, even though the policy was acquired during the marriage and premiums were paid from community funds before premiums were waived by the issuing companies.

STATEMENT OF FACTS

Petitioner Michael A. Brewer and Respondent Deborah *759Q. Brewer were married on May 20, 1988 in Kang County, Washington.1 No children were born of the marriage,2 although Respondent has two children from a prior marriage.3 Respondent has been a full-time elementary school teacher since 1977 with net income between $2,200.00 and $2,300.00 per month.4 At the time of the marriage Petitioner was a dentist who practiced his profession at the Kaiser Company until December 1991 when he was diagnosed with a progressively deteriorating disease, multiple sclerosis.5 *Petitioner was unable to continue the practice of dentistry.6 The Social Security Administration determined him to be permanently disabled. A similar determination was made by the companies issuing his disability insurance policies, Mutual of New York (MONY) and New York Life Insurance Company (NYLIC).7 Petitioner receives a monthly nontaxable income of $6,193.00 from the disability insurance policies and $1,212.00 from Social Security, totaling approximately $7,400.00.8 This is his sole source of income.9

On March 3, 1995 Petitioner served Respondent with a summons and petition for dissolution of marriage which he *760filed in the Clark County Superior Court.10 On March 1, 1996 the Honorable Robert L. Harris signed a decree of dissolution.11 The following statements concerning the disability insurance policies were made by the trial court in the findings of fact and conclusions of law:12

A. The Petitioner’s New York Life and Mutual of New York disability insurance benefits are not assets subject to division in this case. Such benefits should be awarded to the Petitioner Michael Brewer free of any claims of the Respondent Deborah Q. Brewer.
The court notes that the community paid about $12,000 in premiums for such disability pay; however the court also notes that the community received about $6,000 on a monthly basis from these private disability policies, from the time of the Petitioner’s disability until the parties separation, as well as during the period of parties separation under court order which also benefited the parties.
B. Furthermore, the property division in this case is fair and equitable in that it has also taken into account and recognized the disability benefits received and to be received by the Petitioner. The court notes that the Respondent has a substantial separate property estate that the Petitioner does not have. Furthermore, the court has made disproportionate award of community property in favor of the Respondent. The total property award received by Respondent is in excess of that to be received by Petitioner. Such award takes into consideration the fact of the disability payments that Petitioner has and will receive.[13]

Each party was awarded all policies insuring their own lives.14 The parties were to equally divide cassette tapes *761valued at $1,500.00, family photographs, and share reproduction costs for the photographs.15 No maintenance was ordered.16 Child support was not an issue.17 In the findings of fact and conclusions of law the trial court indicated awards to Petitioner of approximately $56,521.00 net value in community assets, plus a marital lien of $10,000.00, and community debts of $11,500.00 for a total of $55,021.00;18 and to Respondent approximately $94,057.00 in community assets less the marital lien of $10,000.00, and community debts of $11,800.00 for a total of $72,257.00.19 Judge Harris determined that, based on this distribution of property, Respondent had a disproportionate award of community property in her favor in addition to approximately $350,000.00 in separate assets, for a total of $422,257.00.20 The value of assets awarded Respondent far exceeded the value of assets awarded to Petitioner.21 The specific values constituting the totals were not indicated precisely by the trial court, but a fair summary and comparison of property awarded the parties in this dissolution is represented in the chart which follows.

*762[[Image here]]

*763[[Image here]]

*764Although the trial court awarded the disability insurance payments to Petitioner Michael A. Brewer as “separate property,” it assigned no value to the policies. The court awarded the family residence in Vancouver, Washington to Respondent as her separate property subject to a lien in favor of Petitioner.22 The trial court determined the community contributed approximately $20,000.00 in funds and labor to the family residence, entitling the marital community to a claim against the home of $20,000.00.23 Petitioner was granted a marital lien of $10,000.00, one-half the total, secured by a note and deed of trust at no interest if paid before July 1, 1996.24 After that date the debt would accrue at 12% per annum until paid.25

In addressing the MONY and NYLIC disability insurance policies, the trial court concluded that the community paid the last actual premiums on all policies immediately prior to the onset of Petitioner’s disability in December 1991,26 after which no further premiums were paid under waiver provisions in the policies.27 The trial court concluded that Respondent Deborah Q. Brewer had no claims to the disability policies28 because (1) the policies were intended to replace future income for Petitioner at income levels he attained before his disability and at levels for a dentist which were expected to increase;29 (2) the policies were not intended for retirement purposes because they terminate when Petitioner reaches age 65 ;30 and (3) the community *765paid approximately $12,000.00 in premiums on the policies and received from them approximately $300,000.00 in monthly disability payments prior to the dissolution.31

The Court of Appeals, the Honorable Karen G. Seinfeld writing, reversed the trial court, holding that the court “erred in ruling that [Dr. Brewer’s] postdissolution disability payments [are] . . . separate property.”32 The case was remanded to allow the trial court to “exercise its discretion to either reaffirm its distribution [of property] or redistribute the property” according to the Court of Appeals’ decision.33 Petitioner then sought review by this court, which was granted on July 8, 1998.

DISCUSSION

Petitioner Michael A. Brewer contends the Court of Appeals erred in ruling that private disability insurance benefits are a divisible asset in a dissolution proceeding. He claims that court’s decision is in conflict with Supreme Court decisions in In re Marriage of Brown34 and In re Marriage of Hall35 and in conflict with prior Court of Appeals decisions in In re Marriage of Huteson36 and In re Marriage of Anglin.37

Respondent Deborah Q. Brewer answers to the contrary that the Court of Appeals was correct. She asserts that the decision is based on Chase v. Chase38 which has not been overruled by Brown, nor is it in conflict with Brown because the cases have different facts and address *766different issues. Neither party disputes the trial court’s findings of fact. They are thus verities on this appeal.39

The principal issue addressed by the Court of Appeals was whether the “trial court err[ed] in characterizing post-dissolution disability payments as [Petitioner Michael A. Brewer’s] separate property.”40 Despite questioning the continued viability of Chase, the Court of Appeals relied upon it in concluding that the trial court mischaracterized as Petitioner’s separate property monthly payments under the disability insurance policies privately purchased with community funds.41

Characterization of property as community or separate is not controlling in division of property between the parties in a dissolution proceeding, but42 “the court must have in mind the correct character and status of the property . . . before any theory of division is ordered.”43 All property, both separate and community, is before the court.44 Under RCW 26.16.010 and RCW 26.16.020 separate property is “[p]roperty and pecuniary rights” owned by each spouse before marriage or acquired afterwards by gift, bequest, devise, descent or inheritance.” Under RCW 26.16.030 community property is property that is not defined as separate property under RCW 26.16.010 or RCW 26.16.020 and is “acquired after marriage by either husband or wife or both . . . .”45 In prior decisions this court has favored characterizing property as community instead of as separate property unless there is clearly no *767question of its character.46 The decision in Chase is consistent with that approach.47

In Chase this court announced the rule that “if . . . premiums are paid with community funds, the insurance proceeds are community property.”48 Respondent asserts “[t]here has been no . . . change or inconsistency in Washington law that mandates essentially rethinking DChase].”49 This assertion is not correct. Chase does not accurately reflect the current law for characterizing proceeds of insurance policies in dissolution proceedings.50 Professor Harry M. Cross, an acknowledged authority on community property in Washington, suggests that the rule announced in Chase that “if the community pays premiums, insurance proceeds are community property” should not apply to disability policies.51 He suggests that disability insurance payments should be characterized in the same manner as tort damages were characterized in Brown 52

Brown, in defining community property, limited it to acquisitions “through the toil, talent or other productive faculty of either spouse, but not compensation for personal injury.”53 Under that definition, the case held tort damages which compensate for services or earnings lost by the community, or for expenses incurred by the community during *768the injury, would be community property54; but tort damages which compensate for pain and suffering to the injured party and injury-related expenses after dissolution of the marriage would be separate property.55 The court reached this conclusion in order to eliminate the inequity of an uninjured spouse sharing in reimbursement of expenses for which that person has no liability.56

A logical application of Brown to privately purchased disability insurance policies suggests that after dissolution of a marriage payment of monthly benefits which constitute future income, or compensation for pain and suffering, should be characterized as separate property even though premium payments were made from community funds during the marriage.57 Insurance compensating for expenses incurred during a marriage or for earnings lost during the marriage or proceeds that in fact constitute deferred compensation should be characterized as community property in proportion to the community’s contribution to those expenses or deferred compensation.58 This court has previously recognized disability payments which are in fact deferred compensation in Arnold v. Department of Retirement Systems.59 Thus, as in Brown, a former spouse not responsible for an injured ex-spouse’s future expenses would not “share in reimbursement for expenses which [that person] ... is not obligated to, and does not, pay.”60

Petitioner asserts that proceeds from privately purchased *769disability insurance policies should not be a divisible asset in marital dissolution proceedings regardless whether they are characterized as separate property or community property.61

Under RCW 26.09.080 trial courts have broad discretion in the distribution of property and liabilities in marriage dissolution proceedings.62 This discretion applies to distribution of monthly payments under privately purchased disability insurance policies acquired during the marriage. Distribution of property by the trial court should be disturbed only if there has been a manifest abuse of discretion.63 The trial court is in the best position to assess the assets and liabilities of the parties and determine what is “fair, just and equitable under all the circumstances.”64

Under the facts of this case, the trial court did not abuse its discretion in distributing future monthly disability payments to Petitioner Michael A. Brewer under the private disability insurance policies purchased during the marriage with premiums paid from community funds. The community paid $12,000.00 in premiums on the policies and received disability payments totaling $300,000.00 prior to the dissolution.65 In making distribution to the parties, the *770trial court properly determined what was fair, just and equitable under all of the circumstances.

SUMMARY AND CONCLUSIONS

The Court of Appeals agreed with the trial court only in its distribution of property in this dissolution, but disagreed with its comments that it felt bound to award future disability payments under the disability insurance policies to Petitioner Michael A. Brewer as his separate property. The Court of Appeals, relying upon Chase v. Chase,66 concluded that disability insurance payments were community property. But this Court in Marriage of Brown,67 has moved away from such an absolute conclusion.

Under Brown, monthly payments under a disability insurance policy intended to compensate the insured for future income or pain and suffering should be characterized as separate property. Monthly payments under the policy which compensate for expenses incurred during the marriage, or earnings lost during the marriage or payments which are in fact deferred compensation, should be characterized as community property in proportion to the community’s contribution to those expenses or to the deferred compensation plan.

Although under RCW 26.09.080 the trial court in a dis-soultion proceeding must consider the character and status of property before distribution, the actual characterization of property as community or separate is not essential to the exercise of discretion by the trial court in distributing assets and liabilities. The trial court under the facts of this case, in the exercise of its discretion, could award future disability payments to Petitioner Michael A. Brewer, regardless whether those payments are characterized as community property or separate property. The fact the trial court characterized the disability policies as separate prop*771erty, even if in error, would not affect the discretionary disposition to Petitioner Michael A. Brewer. The trial court, under Brown, could properly characterize the monthly disability payments after the dissolution as the separate property of Petitioner Michael A. Brewer.

We therefore disagree with the Court of Appeals only in its determination that remand to the trial court was necessary. Any error committed by the trial court in concluding the disability insurance benefits were not assets subject to division was cured by the authority given courts under RCW 26.09.080 to divide both community property and separate property between the parties in a marriage dissolution, keeping in mind the correct character and status of the property and determining what is “fair, just and equitable, under all the circumstances.”

We conclude instead that the privately purchased disability insurance policies (Mutual of New York and New York Life Insurance Company) for Petititoner Michael A. Brewer acquired during the marriage with premiums paid from community funds retained their character as community property until the dissolution; but after the dissolution monthly payments to Petitioner Michael A. Brewer changed in character to his separate property. The trial court incorrectly concluded the disability insurance benefits were “not assets subject to division in this case.”68

We agree with the Court of Appeals on its conclusion that property distribution in this case was proper, but disagree only with that portion of its decision which remanded the case to the Clark County Superior Court. In so doing, we affirm the decision of the trial court which awarded to Petitioner Michael A. Brewer as his separate property future monthly disability payments under the private disability insurance policies purchased during his marriage to Respondent Deborah Q. Brewer with premiums paid from community funds during the marriage until the premiums were waived by the companies issuing the policies.

*772Johnson, Talmadge, Sanders, and Ireland, JJ., concur.

Clerk’s Papers at 243. On May 20, 1988 the parties entered into a prenuptial agreement, listing most of their premarital assets and debts, which was not directly related to the disputed ruling and is not in the record before this court. Clerk’s Paper at 244. +

Id. at 250. +

Id. at 249. +

Id. +

Id. Multiple sclerosis is a chronic disease in which there is scattered demyelination of the central nervous system principally characterized by speech defects and loss of muscular coordination. Webster’s New World Dictionary (2d College ed. 1986). +

Clerk’s Papers at 249. +

Id. The record does not include documentation from the Social Security Administration nor copies of the disability insurance policies. +

Id. This includes $2,793.00 per month from the NYLIC disability policy, earned by Petitioner during the marriage as a job-related benefit at Kaiser. The two privately purchased MONY disability policies pay $1,000.00 and $2,400.00 per month. +

Id. +

Id. at 1-5. +

Id. at 269-71. +

Id. at 243-53. +

13Id. at 252-53 (emphasis added). +

Id. at 246. +

Id. at 247. +

Id. at 248. +

Id. at 250. Respondent receives Social Security payments as a result of her former husband’s death which she uses for her children’s living expenses. She receives $839.00 per month for her youngest child, and might receive an additional $839.00 for the older child if she successfully appeals the Social Security allocation. Her children also have trust resources to provide for educational and related expenses. Clerk’s Papers at 249. +

Id. at 247-48. +

Id. at 248. +

Id. at 250. +

Id. +

Id. at 245. +

Id. +

Id. +

Id. +

Id. at 250-51. +

Id. +

Id. at 251, 252. +

Id. at 251. +

Id. Petitioner presented testimony at trial that he cannot reasonably expect to reach the “retirement” age of 65 years because his illness has reduced his life expectancy to 45 years. +

In re Marriage of Brewer, 89 Wn. App. 425, 427, 949 P.2d 404 (1998). See also Clerks Fapers at 252. +

Id. at 430. +

Id. at 431. +

100 Wn.2d 729, 675 P.2d 1207 (1984). +

103 Wn.2d 236, 692 P.2d 175 (1984). +

27 Wn. App. 539, 619 P.2d 991 (1980). +

52 Wn. App. 317, 759 P.2d 1224 (1988). +

74 Wn.2d 253, 444 P.2d 145 (1968). +

Moreman v. Butcher, 126 Wn.2d 36, 39, 891 P.2d 725 (1995). +

Brewer, 89 Wn. App. at 426. +

ld. at 430. +

Blood v. Blood, 69 Wn.2d 680, 682, 419 P.2d 1006 (1966). +

Id. +

Friedlander v. Friedlander; 80 Wn.2d 293, 303, 494 P.2d 208 (1972). +

RCW 26.16.030; see also Harxy M. Cross, The Community Property Law in Washington (Revised 1985), 61 Wash. L. Rev. 17, 28 (1986). +

Cross, supra; see In re Marriage of Brown, 100 Wn.2d 729, 734, 675 P.2d 1207 (1984) (citing In re Marriage of Parsons, 28 Wn. App. 276, 622 P.2d 415, review denied, 95 Wn.2d 1019 (1981)). +

Chase 74 Wn.2d at 257 (“Favoring, as it does, the existence of community as opposed to separate property, the law will resolve the doubts between them in favor of a community status.”). +

Id. +

Answer to Pet. for Review of Deborah Brewer at 6. +

Aetna Life Ins. Co. v. Wadsworth, 102 Wn.2d 652, 659, 689 P.2d 46 (1984) (“[T]he character of funds used to pay for the most recent term should determine the character of a term life insurance policy.”). +

Cross, supra, note 46, at 64-65. +

Id. +

Brown, 100 Wn.2d at 737. +

Id. at 738. +

Id. +

Id. 738-39. +

Cross, supra, note, at 64-65. +

Id. +

128 Wn.2d 765, 778, 912 P.2d 463 (1996) (“Despite the general community property presumption under RCW 26.16.030, Washington courts have refused to treat disability income, including disability pensions, as community assets subject to allocation in a dissolution proceeding in the absence of substantial elements of either deferred compensation or retirement. Such payments are for lost future income and are not ‘earned’ as are retirement benefits.”). See also In re Marriage of Kollmer, 73 Wn. App. 373, 870 P.2d 978 (1994). +

Brown, 100 Wn.2d at 738-39. +

Supplemental Br. of Pet’r at 5. +

In re Marriage of Konzen, 103 Wn.2d 470, 477-78, 693 P.2d 97 (1985) (former RCW 26.09.080 provides “[T]he court shall, without regard to marital misconduct, make such disposition of the property and liabilities of the parties, either community or separate, as shall appear just and equitable after considering all relevant factors including, but not limited to: (1) [t]he nature and extent of the community property; (2) [t]he nature and extent of the separate property; (3) [t]he duration of the marriage; and (4) [t]he economic circumstances of each spouse at the time the division of property is to become effective, including the desirability of awarding the family home or the right to live [in it] . . . for reasonable periods to a spouse having custody of any children.” (emphasis added)). +

Konzen 103 Wn.2d at 478. +

In re Marriage of Hadley, 88 Wn.2d 649, 656, 565 P.2d 790 (1977) (citing Baker v. Baker, 80 Wn.2d 736, 498 P.2d 315 (1972)). +

Brewer 89 Wn. App. at 427. See also Clerk’s Eapers at 252. +

74 Wn.2d 253, 444 P.2d 145 (1968). +

100 Wn.2d 729, 675 P.2d 1207 (1984). +

Clerk’s Papers at 252.

Case-law data current through December 31, 2025. Source: CourtListener bulk data.

↑ + \ No newline at end of file diff --git a/.research/brewer.txt b/.research/brewer.txt new file mode 100644 index 0000000..d504a7c --- /dev/null +++ b/.research/brewer.txt @@ -0,0 +1 @@ +In re the Marriage of Brewer, 137 Wash. 2d 756 (Wash. 1999) | HallApproved.com Hall Approved Free Access to American Case Law Statutes Free Legal Archive / Washington / Cases / Washington Supreme Court / 1999 / Washington Supreme Court, 1999 Copy citation Free Legal Archive / Washington / Cases / Washington Supreme Court / 1999 / In re the Marriage of Brewer In re the Marriage of Brewer Washington Supreme Court · Decided May 6, 1999 · Guy, Smith 137 Wash. 2d 756; 976 P.2d 102; 1999 Wash. LEXIS 284 In re the Marriage of Brewer Opinions Concurring Opinion Opinion of the Court Concurring Opinion Guy, C.J. (concurring) — I agree with the majority that the rule enunciated in In re Marriage of Brown, 100 Wn.2d 729 , 675 P.2d 1207 (1984), applies to wage-replacement disability insurance benefits. I write separately because (1) I would specifically overrule Chase v. Chase, 74 Wn.2d 253 , 444 P.2d 145 (1968), and (2) I would clarify that post-dissolution wage-replacement benefits are not “assets” that are before the trial court in a dissolution proceeding. Courts and commentators alike have recognized the inconsistency in Washington’s case law in this area. See, e.g., In re Marriage of Huteson, 27 Wn. App. 539, 542-43 , 619 P.2d 991 (1980) (questioning both the logic and wisdom of Chase, and holding “To treat . . . disability payments as a community asset would unfairly and permanently burden those future earnings to the same extent as would an award of permanent alimony.”); In re Marriage of Brewer, 89 Wn. App. 425, 430 , 949 P.2d 404 (1998) (noting that, in light of criticism and newer case law, the continuing viability of the Chase rule “is questionable”) 69 ; 1 Washington State Bar Ass’n, Family Law Deskbook § 38.3(5), at SU-38-2 (Supp. 1996) (“The status of Washington law as to when disability benefits to be paid after entry of a decree constitute ‘property’ subject to distribution by the trial court in a dissolution action is ‘not all together clear.’ In fact, some Washington cases classify disability benefits as property subject to distribution, others classify them as income not subject to distribution, and still others classify disability benefits as part property and part income.”); Harry M. Cross, The Community Property Law in Washington (Revised 1985), 61 Wash. L. Rev. 13 , 64 (1986) (“the proper treatment of disability insurance or pension payments . . . should be reconsidered in light of the decision in Brown”); 20 Kenneth W Weber, Washington Eractice: Family and Community *773 Property Law § 32.17, at 190-91 (1997) (“retirement benefits are generally considered deferred compensation for past services, and . . . are considered an asset and divisible as such. ... By contrast, disability benefits that are in the nature of compensation for lost future wages (sometimes called future earnings replacement) are generally not an asset for distribution upon dissolution, though contrary results have been reached in a few cases.” (footnote omitted). The authors of the State Bar Association Community Property Deskbook state: Disability payments normally represent compensation for diminished earning capacity, replacing lost wages. Thus viewed, the payments are not a form of deferred compensation, rather they are a form of current compensation. The California courts have held that disability payments received during marriage will be considered community property. Payments to be received after dissolution of marriage will be considered separate property. This result should be reached in Washington under the reasoning of In re Marriage of Brown .... Earlier cases, however, reached a contrary result. Washington State Bar Ass’n, Community Property Deskbook § 3.24, at 3-31 to 3-32 (2d ed. 1989) (citation omitted). See also In re Marriage of Nuss, 65 Wn. App. 334, 343 , 828 P.2d 627 (1992) (disability benefits which are in the nature of compensation for lost future wages are not an asset for distribution upon dissolution; by contrast, disability benefits which are in the nature of deferred compensation or retirement pay are community property); In re Marriage of Anglin, 52 Wn. App. 317, 324 , 759 P.2d 1224 (1988) (disability benefits characterized as repayment for lost future wages were not a marital asset to be characterized and distributed by the court). In my view, we should clarify the law by overruling Chase and hold: Disability payments which are in the nature of earnings replacement are treated the same as the earnings *774 of a healthy spouse. Therefore, when the parties are married and not separated, the replacement earnings would be community property; assets purchased with or generated by community funds are assets belonging to the community. RCW 26.16.030. When the parties are separated, their earnings—whether a result of wage replacement disability benefits or of personal labor—are separate property. RCW 26.16.140. Future, postdissolution earnings, whether received from employment, business ventures, investment, or disability benefits, are not “assets” which are before the court for disposition in a dissolution action. See Brown, 100 Wn.2d at 738 ; In re Marriage of Hall, 103 Wn.2d 236, 247 , 692 P.2d 175 (1984) (future earning capacity is not a marital asset). However, the trial court may consider such earnings when determining what constitutes a fair and equitable distribution of the assets and debts which are before the court. RCW 26.09.080 (economic circumstances of each spouse is a relevant factor in making a property disposition); Hall, 103 Wn.2d at 247 ; In re Marriage of Leland, 69 Wn. App. 57, 72 , 847 P.2d 518 (1993). The trial court also may consider such earnings when determining the propriety and amount of any maintenance award. RCW 26.09.090. Durham, Madsen, and Alexander, JJ., concur with Guy, C.J. Because of the similarity of the facts in this case and those in Chase v. Chase, 74 Wn.2d 253 , 444 P.2d 145 (1968), I cannot fault the Court of Appeals for feeling—reluctantly—bound to follow the rule articulated in Chase . Opinion of the Court Smith, J. Petitioner Michael A. Brewer seeks review of a decision of the Court of Appeals, Division Two, which reversed and remanded to the Clark County Superior Court a ruling characterizing monthly payments to a permanently disabled spouse under a private disability insurance policy after dissolution of a marriage as separate property and not community property. We granted review. We affirm the Court of Appeals in part and reverse it in part. QUESTION PRESENTED The question presented in this case is whether monthly payments to a permanently disabled spouse under a private disability insurance policy after dissolution of a marriage constitutes separate property and not community property, even though the policy was acquired during the marriage and premiums were paid from community funds before premiums were waived by the issuing companies. STATEMENT OF FACTS Petitioner Michael A. Brewer and Respondent Deborah *759 Q. Brewer were married on May 20, 1988 in Kang County, Washington. 1 No children were born of the marriage, 2 although Respondent has two children from a prior marriage. 3 Respondent has been a full-time elementary school teacher since 1977 with net income between $2,200.00 and $2,300.00 per month. 4 At the time of the marriage Petitioner was a dentist who practiced his profession at the Kaiser Company until December 1991 when he was diagnosed with a progressively deteriorating disease, multiple sclerosis. 5 *Petitioner was unable to continue the practice of dentistry. 6 The Social Security Administration determined him to be permanently disabled. A similar determination was made by the companies issuing his disability insurance policies, Mutual of New York (MONY) and New York Life Insurance Company (NYLIC). 7 Petitioner receives a monthly nontaxable income of $6,193.00 from the disability insurance policies and $1,212.00 from Social Security, totaling approximately $7,400.00. 8 This is his sole source of income. 9 On March 3, 1995 Petitioner served Respondent with a summons and petition for dissolution of marriage which he *760 filed in the Clark County Superior Court. 10 On March 1, 1996 the Honorable Robert L. Harris signed a decree of dissolution. 11 The following statements concerning the disability insurance policies were made by the trial court in the findings of fact and conclusions of law: 12 A. The Petitioner’s New York Life and Mutual of New York disability insurance benefits are not assets subject to division in this case. Such benefits should be awarded to the Petitioner Michael Brewer free of any claims of the Respondent Deborah Q. Brewer. The court notes that the community paid about $12,000 in premiums for such disability pay; however the court also notes that the community received about $6,000 on a monthly basis from these private disability policies, from the time of the Petitioner’s disability until the parties separation, as well as during the period of parties separation under court order which also benefited the parties. B. Furthermore, the property division in this case is fair and equitable in that it has also taken into account and recognized the disability benefits received and to be received by the Petitioner. The court notes that the Respondent has a substantial separate property estate that the Petitioner does not have. Furthermore, the court has made disproportionate award of community property in favor of the Respondent. The total property award received by Respondent is in excess of that to be received by Petitioner. Such award takes into consideration the fact of the disability payments that Petitioner has and will receive. [13] Each party was awarded all policies insuring their own lives. 14 The parties were to equally divide cassette tapes *761 valued at $1,500.00, family photographs, and share reproduction costs for the photographs. 15 No maintenance was ordered. 16 Child support was not an issue. 17 In the findings of fact and conclusions of law the trial court indicated awards to Petitioner of approximately $56,521.00 net value in community assets, plus a marital lien of $10,000.00, and community debts of $11,500.00 for a total of $55,021.00; 18 and to Respondent approximately $94,057.00 in community assets less the marital lien of $10,000.00, and community debts of $11,800.00 for a total of $72,257.00. 19 Judge Harris determined that, based on this distribution of property, Respondent had a disproportionate award of community property in her favor in addition to approximately $350,000.00 in separate assets, for a total of $422,257.00. 20 The value of assets awarded Respondent far exceeded the value of assets awarded to Petitioner. 21 The specific values constituting the totals were not indicated precisely by the trial court, but a fair summary and comparison of property awarded the parties in this dissolution is represented in the chart which follows. *762 [[Image here]] *763 [[Image here]] *764 Although the trial court awarded the disability insurance payments to Petitioner Michael A. Brewer as “separate property,” it assigned no value to the policies. The court awarded the family residence in Vancouver, Washington to Respondent as her separate property subject to a lien in favor of Petitioner. 22 The trial court determined the community contributed approximately $20,000.00 in funds and labor to the family residence, entitling the marital community to a claim against the home of $20,000.00. 23 Petitioner was granted a marital lien of $10,000.00, one-half the total, secured by a note and deed of trust at no interest if paid before July 1, 1996. 24 After that date the debt would accrue at 12% per annum until paid. 25 In addressing the MONY and NYLIC disability insurance policies, the trial court concluded that the community paid the last actual premiums on all policies immediately prior to the onset of Petitioner’s disability in December 1991, 26 after which no further premiums were paid under waiver provisions in the policies. 27 The trial court concluded that Respondent Deborah Q. Brewer had no claims to the disability policies 28 because (1) the policies were intended to replace future income for Petitioner at income levels he attained before his disability and at levels for a dentist which were expected to increase; 29 (2) the policies were not intended for retirement purposes because they terminate when Petitioner reaches age 65 ; 30 and (3) the community *765 paid approximately $12,000.00 in premiums on the policies and received from them approximately $300,000.00 in monthly disability payments prior to the dissolution. 31 The Court of Appeals, the Honorable Karen G. Seinfeld writing, reversed the trial court, holding that the court “erred in ruling that [Dr. Brewer’s] postdissolution disability payments [are] . . . separate property.” 32 The case was remanded to allow the trial court to “exercise its discretion to either reaffirm its distribution [of property] or redistribute the property” according to the Court of Appeals’ decision. 33 Petitioner then sought review by this court, which was granted on July 8, 1998. DISCUSSION Petitioner Michael A. Brewer contends the Court of Appeals erred in ruling that private disability insurance benefits are a divisible asset in a dissolution proceeding. He claims that court’s decision is in conflict with Supreme Court decisions in In re Marriage of Brown 34 and In re Marriage of Hall 35 and in conflict with prior Court of Appeals decisions in In re Marriage of Huteson 36 and In re Marriage of Anglin. 37 Respondent Deborah Q. Brewer answers to the contrary that the Court of Appeals was correct. She asserts that the decision is based on Chase v. Chase 38 which has not been overruled by Brown, nor is it in conflict with Brown because the cases have different facts and address *766 different issues. Neither party disputes the trial court’s findings of fact. They are thus verities on this appeal. 39 The principal issue addressed by the Court of Appeals was whether the “trial court err[ed] in characterizing post-dissolution disability payments as [Petitioner Michael A. Brewer’s] separate property.” 40 Despite questioning the continued viability of Chase, the Court of Appeals relied upon it in concluding that the trial court mischaracterized as Petitioner’s separate property monthly payments under the disability insurance policies privately purchased with community funds. 41 Characterization of property as community or separate is not controlling in division of property between the parties in a dissolution proceeding, but 42 “the court must have in mind the correct character and status of the property . . . before any theory of division is ordered.” 43 All property, both separate and community, is before the court. 44 Under RCW 26.16.010 and RCW 26.16.020 separate property is “[p]roperty and pecuniary rights” owned by each spouse before marriage or acquired afterwards by gift, bequest, devise, descent or inheritance.” Under RCW 26.16.030 community property is property that is not defined as separate property under RCW 26.16.010 or RCW 26.16.020 and is “acquired after marriage by either husband or wife or both . . . .” 45 In prior decisions this court has favored characterizing property as community instead of as separate property unless there is clearly no *767 question of its character. 46 The decision in Chase is consistent with that approach. 47 In Chase this court announced the rule that “if . . . premiums are paid with community funds, the insurance proceeds are community property.” 48 Respondent asserts “[t]here has been no . . . change or inconsistency in Washington law that mandates essentially rethinking DChase].” 49 This assertion is not correct. Chase does not accurately reflect the current law for characterizing proceeds of insurance policies in dissolution proceedings. 50 Professor Harry M. Cross, an acknowledged authority on community property in Washington, suggests that the rule announced in Chase that “if the community pays premiums, insurance proceeds are community property” should not apply to disability policies. 51 He suggests that disability insurance payments should be characterized in the same manner as tort damages were characterized in Brown 52 Brown, in defining community property, limited it to acquisitions “through the toil, talent or other productive faculty of either spouse, but not compensation for personal injury.” 53 Under that definition, the case held tort damages which compensate for services or earnings lost by the community, or for expenses incurred by the community during *768 the injury, would be community property 54 ; but tort damages which compensate for pain and suffering to the injured party and injury-related expenses after dissolution of the marriage would be separate property. 55 The court reached this conclusion in order to eliminate the inequity of an uninjured spouse sharing in reimbursement of expenses for which that person has no liability. 56 A logical application of Brown to privately purchased disability insurance policies suggests that after dissolution of a marriage payment of monthly benefits which constitute future income, or compensation for pain and suffering, should be characterized as separate property even though premium payments were made from community funds during the marriage. 57 Insurance compensating for expenses incurred during a marriage or for earnings lost during the marriage or proceeds that in fact constitute deferred compensation should be characterized as community property in proportion to the community’s contribution to those expenses or deferred compensation. 58 This court has previously recognized disability payments which are in fact deferred compensation in Arnold v. Department of Retirement Systems. 59 Thus, as in Brown, a former spouse not responsible for an injured ex-spouse’s future expenses would not “share in reimbursement for expenses which [that person] ... is not obligated to, and does not, pay.” 60 Petitioner asserts that proceeds from privately purchased *769 disability insurance policies should not be a divisible asset in marital dissolution proceedings regardless whether they are characterized as separate property or community property. 61 Under RCW 26.09.080 trial courts have broad discretion in the distribution of property and liabilities in marriage dissolution proceedings. 62 This discretion applies to distribution of monthly payments under privately purchased disability insurance policies acquired during the marriage. Distribution of property by the trial court should be disturbed only if there has been a manifest abuse of discretion. 63 The trial court is in the best position to assess the assets and liabilities of the parties and determine what is “fair, just and equitable under all the circumstances.” 64 Under the facts of this case, the trial court did not abuse its discretion in distributing future monthly disability payments to Petitioner Michael A. Brewer under the private disability insurance policies purchased during the marriage with premiums paid from community funds. The community paid $12,000.00 in premiums on the policies and received disability payments totaling $300,000.00 prior to the dissolution. 65 In making distribution to the parties, the *770 trial court properly determined what was fair, just and equitable under all of the circumstances. SUMMARY AND CONCLUSIONS The Court of Appeals agreed with the trial court only in its distribution of property in this dissolution, but disagreed with its comments that it felt bound to award future disability payments under the disability insurance policies to Petitioner Michael A. Brewer as his separate property. The Court of Appeals, relying upon Chase v. Chase, 66 concluded that disability insurance payments were community property. But this Court in Marriage of Brown, 67 has moved away from such an absolute conclusion. Under Brown, monthly payments under a disability insurance policy intended to compensate the insured for future income or pain and suffering should be characterized as separate property. Monthly payments under the policy which compensate for expenses incurred during the marriage, or earnings lost during the marriage or payments which are in fact deferred compensation, should be characterized as community property in proportion to the community’s contribution to those expenses or to the deferred compensation plan. Although under RCW 26.09.080 the trial court in a dis-soultion proceeding must consider the character and status of property before distribution, the actual characterization of property as community or separate is not essential to the exercise of discretion by the trial court in distributing assets and liabilities. The trial court under the facts of this case, in the exercise of its discretion, could award future disability payments to Petitioner Michael A. Brewer, regardless whether those payments are characterized as community property or separate property. The fact the trial court characterized the disability policies as separate prop *771 erty, even if in error, would not affect the discretionary disposition to Petitioner Michael A. Brewer. The trial court, under Brown, could properly characterize the monthly disability payments after the dissolution as the separate property of Petitioner Michael A. Brewer. We therefore disagree with the Court of Appeals only in its determination that remand to the trial court was necessary. Any error committed by the trial court in concluding the disability insurance benefits were not assets subject to division was cured by the authority given courts under RCW 26.09.080 to divide both community property and separate property between the parties in a marriage dissolution, keeping in mind the correct character and status of the property and determining what is “fair, just and equitable, under all the circumstances.” We conclude instead that the privately purchased disability insurance policies (Mutual of New York and New York Life Insurance Company) for Petititoner Michael A. Brewer acquired during the marriage with premiums paid from community funds retained their character as community property until the dissolution; but after the dissolution monthly payments to Petitioner Michael A. Brewer changed in character to his separate property. The trial court incorrectly concluded the disability insurance benefits were “not assets subject to division in this case.” 68 We agree with the Court of Appeals on its conclusion that property distribution in this case was proper, but disagree only with that portion of its decision which remanded the case to the Clark County Superior Court. In so doing, we affirm the decision of the trial court which awarded to Petitioner Michael A. Brewer as his separate property future monthly disability payments under the private disability insurance policies purchased during his marriage to Respondent Deborah Q. Brewer with premiums paid from community funds during the marriage until the premiums were waived by the companies issuing the policies. *772 Johnson, Talmadge, Sanders, and Ireland, JJ., concur. Clerk’s Papers at 243. On May 20, 1988 the parties entered into a prenuptial agreement, listing most of their premarital assets and debts, which was not directly related to the disputed ruling and is not in the record before this court. Clerk’s Paper at 244. Id. at 250. Id. at 249. Id. Id. Multiple sclerosis is a chronic disease in which there is scattered demyelination of the central nervous system principally characterized by speech defects and loss of muscular coordination. Webster’s New World Dictionary (2d College ed. 1986). Clerk’s Papers at 249. Id. The record does not include documentation from the Social Security Administration nor copies of the disability insurance policies. Id. This includes $2,793.00 per month from the NYLIC disability policy, earned by Petitioner during the marriage as a job-related benefit at Kaiser. The two privately purchased MONY disability policies pay $1,000.00 and $2,400.00 per month. Id. Id. at 1-5. Id. at 269-71. Id. at 243-53. 13Id. at 252-53 (emphasis added). Id. at 246. Id. at 247. Id. at 248. Id. at 250. Respondent receives Social Security payments as a result of her former husband’s death which she uses for her children’s living expenses. She receives $839.00 per month for her youngest child, and might receive an additional $839.00 for the older child if she successfully appeals the Social Security allocation. Her children also have trust resources to provide for educational and related expenses. Clerk’s Papers at 249. Id. at 247-48. Id. at 248. Id. at 250. Id. Id. at 245. Id. Id. Id. Id. at 250-51. Id. Id. at 251, 252. Id. at 251. Id. Petitioner presented testimony at trial that he cannot reasonably expect to reach the “retirement” age of 65 years because his illness has reduced his life expectancy to 45 years. In re Marriage of Brewer, 89 Wn. App. 425, 427 , 949 P.2d 404 (1998). See also Clerks Fapers at 252. Id. at 430 . Id. at 431 . 100 Wn.2d 729 , 675 P.2d 1207 (1984). 103 Wn.2d 236 , 692 P.2d 175 (1984). 27 Wn. App. 539 , 619 P.2d 991 (1980). 52 Wn. App. 317 , 759 P.2d 1224 (1988). 74 Wn.2d 253 , 444 P.2d 145 (1968). Moreman v. Butcher, 126 Wn.2d 36, 39 , 891 P.2d 725 (1995). Brewer, 89 Wn. App. at 426 . ld. at 430. Blood v. Blood, 69 Wn.2d 680, 682 , 419 P.2d 1006 (1966). Id. Friedlander v. Friedlander; 80 Wn.2d 293, 303 , 494 P.2d 208 (1972). RCW 26.16.030; see also Harxy M. Cross, The Community Property Law in Washington (Revised 1985), 61 Wash. L. Rev. 17 , 28 (1986). Cross, supra; see In re Marriage of Brown, 100 Wn.2d 729, 734 , 675 P.2d 1207 (1984) (citing In re Marriage of Parsons, 28 Wn. App. 276 , 622 P.2d 415 , review denied, 95 Wn.2d 1019 (1981)). Chase 74 Wn.2d at 257 (“Favoring, as it does, the existence of community as opposed to separate property, the law will resolve the doubts between them in favor of a community status.”). Id. Answer to Pet. for Review of Deborah Brewer at 6. Aetna Life Ins. Co. v. Wadsworth, 102 Wn.2d 652, 659 , 689 P.2d 46 (1984) (“[T]he character of funds used to pay for the most recent term should determine the character of a term life insurance policy.”). Cross, supra, note 46, at 64-65. Id. Brown, 100 Wn.2d at 737 . Id. at 738 . Id. Id. 738-39 . Cross, supra, note, at 64-65. Id. 128 Wn.2d 765, 778 , 912 P.2d 463 (1996) (“Despite the general community property presumption under RCW 26.16.030, Washington courts have refused to treat disability income, including disability pensions, as community assets subject to allocation in a dissolution proceeding in the absence of substantial elements of either deferred compensation or retirement. Such payments are for lost future income and are not ‘earned’ as are retirement benefits.”). See also In re Marriage of Kollmer, 73 Wn. App. 373 , 870 P.2d 978 (1994). Brown, 100 Wn.2d at 738-39 . Supplemental Br. of Pet’r at 5. In re Marriage of Konzen, 103 Wn.2d 470, 477-78 , 693 P.2d 97 (1985) (former RCW 26.09.080 provides “[T]he court shall, without regard to marital misconduct, make such disposition of the property and liabilities of the parties, either community or separate, as shall appear just and equitable after considering all relevant factors including, but not limited to: (1) [t]he nature and extent of the community property; (2) [t]he nature and extent of the separate property; (3) [t]he duration of the marriage; and (4) [t]he economic circumstances of each spouse at the time the division of property is to become effective, including the desirability of awarding the family home or the right to live [in it] . . . for reasonable periods to a spouse having custody of any children.” (emphasis added)). Konzen 103 Wn.2d at 478 . In re Marriage of Hadley, 88 Wn.2d 649, 656 , 565 P.2d 790 (1977) (citing Baker v. Baker, 80 Wn.2d 736 , 498 P.2d 315 (1972)). Brewer 89 Wn. App. at 427 . See also Clerk’s Eapers at 252. 74 Wn.2d 253 , 444 P.2d 145 (1968). 100 Wn.2d 729 , 675 P.2d 1207 (1984). Clerk’s Papers at 252. Case-law data current through December 31, 2025. Source: CourtListener bulk data . A public interest project of Aaron Hall, Attorney at Law © 2026 About Federal Minnesota California New York Texas Terms Data from CourtListener / Free Law Project ↑ \ No newline at end of file diff --git a/.research/brown.html b/.research/brown.html new file mode 100644 index 0000000..4307e87 --- /dev/null +++ b/.research/brown.html @@ -0,0 +1,157 @@ +In Re the Marriage of Brown, 675 P.2d 1207 (Wash. 1984) | HallApproved.com
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Washington Supreme Court, 1984 +

In Re the Marriage of Brown

In Re the Marriage of Brown
Washington Supreme Court · Decided January 12, 1984 · Dimmick
675 P.2d 1207; 100 Wash. 2d 729; 1984 Wash. LEXIS 1445 +(Pacific Reporter, Second Series)

In Re the Marriage of Brown

Opinion

*730 +Dimmick, J.

When a third party tortfeasor injures a spouse during the marriage, how should the potential recovery on the personal injury claim be characterized for purposes of distribution in a subsequent dissolution proceeding? The Court of Appeals, Division One, held that Ronna Brown's potential recovery for an injury sustained during her marriage was community property. We reverse. Under our opinion today, recovery for an injury inflicted upon a married person by a third party tortfeasor is the separate property of the injured spouse, except to the extent the recovery compensates the community for lost wages which would have been community property, or injury-related expenses which the community incurred. The disposition of Ronna's potential recovery entered by the trial judge, which was reversed by the Court of Appeals, is in accord with our holding and is reinstated.

I

Ronna and William L. Brown were married on January 27, 1967. In October 1975, Ronna filed for dissolution. The parties later reconciled and the action was dismissed. Prior to this dismissal, the parties entered into a postnuptial agreement. The agreement provided that certain assets were separate and others were community. It further stated that in the event of dissolution each party would be awarded his or her separate property and all of the community property accumulated by the parties would be equally divided.

In September 1979, Ronna instituted a second dissolution action. In this action, both parties agreed that the postnuptial agreement was valid and binding. The trial judge considered herself bound by the agreement and divided the property accordingly.

Approximately 6 months before the second action was filed, Ronna had been injured in an automobile accident. At trial, no cross examination concerning her injury or the value of her potential recovery was permitted. Out-of-pocket expenses relating to her injury and incurred prior to +*731 +trial had been reimbursed in full. The trial court characterized her potential recovery as follows:

a. Recovery for out of pocket expenses incurred after trial is the separate property of the party incurring said expenses and should be awarded to that party.
b. Recovery for petitioner's lost earnings and diminished earning capacity from the date of the accident until the date of separation, September 4, 1979, is community property and should be awarded one-half to each party.
c. Recovery for petitioner's lost earnings and diminished earning capacity after the date of separation, September 4, 1979, is the separate property of the petitioner and should be awarded to her.
d. Recovery for all other damages is the separate property of the petitioner and should be awarded to her. The control of the litigation should repose with the petitioner who should have exclusive authority to compromise the claim. In the event the case is submitted to the jury trial the above allocation of the damages should proceed upon special interrogatories.

Conclusion of law 6.A.7. Clerk's Papers, at 19-20.

William appealed. The Court of Appeals reversed, holding that Ronna's third party tort claim was community property.

II

The established rule in Washington has heretofore been that recovery for injuries to a married person by a third party tortfeasor is community property. +Freehe v. Freehe, +81 Wn.2d 183, 191, 500 P.2d 771 (1972).

This rule has its genesis in the early case of +Hawkins v. Front St. Cable Ry., +3 Wash. 592, 28 P. 1021 (1892). +Hawkins +was a tort action brought by husband and wife to recover damages resulting from injuries received by the wife while riding as a passenger on a streetcar. The defendant tortfeasor challenged an instruction which permitted the jury to take the husband's loss of his wife's services into consideration in computing damages. This court upheld the instruction on the following reasoning:

At common law, when a wife was injured through the tort of a third person, the injury and the right of action
*732 +were hers, but she could not sue unless her husband, if living, joined her as plaintiff. The recovery in that case was the pecuniary measure of her own injury and suffering in body and mind. But there was another element of damage which could be recovered only by her husband suing alone in a separate action, viz., his loss of her services and his outlay in restoring her to health. . . .
. . . +But inasmuch as the right to sue for a tort which one has suffered is a chose in action, and therefore property, in those states where, as here, all property acquired by either spouse otherwise than by gift, bequest, devise or descent is common or community property, this chose in action is suable by that member of the community who has the disposition of the community personalty. . . .
... In this case, therefore, the husband was the only necessary party, though the wife, by §7, Code of 1881, is a proper party, and in this action all of the damages naturally flowing from the injury complained of are recoverable.

(Italics ours.) +Hawkins, +at 595-96.

Thus, the issue in +Hawkins +was whether the plaintiff husband could recover damages for the loss of his wife's services in an action brought for personal injury to his wife. The +Hawkins +court found it necessary to characterize the personal injury claim in order to determine what role the husband played as a plaintiff in the action. Because the claim was community property, it followed that the husband was suing in his capacity as manager of the community personalty, and all damages were recoverable in the one community action.

The +Hawkins +rule that a claim for personal injury to a married person by a third party tortfeasor is community property was consistently followed in subsequent decisions of this court. +See, e.g., Chase v. Beard, +55 Wn.2d 58, 346 P.2d 315 (1959); +Ostheller v. Spokane & I.E. R.R., +107 Wash. 678, 182 P. 630 (1919); +Hammond v. Jackson, +89 Wash. 510, 154 P. 1106 (1916). Although the rule was applied in a variety of contexts, many of the early cases applied it to hold that the husband, as manager of the +*733 +community personalty, was a necessary party to the wife's action for personal injury sustained during the marriage. +See, e.g., Clark v. Beggs, +138 Wash. 62, 244 P. 121 (1926); +Hynes v. Colman Dock Co., +108 Wash. 642, 185 P. 617 (1919); +Schneider v. Biberger, +76 Wash. 504, 136 P. 701, 6 A.L.R. 1056 (1913).

In 1972, the State Legislature amended the community property statutes to grant the wife equal power to manage and control community property. RCW 26.16.030. This change made +Hawkins +and its progeny obsolete to the extent they had held that the husband, as manager of the community property, was a necessary party to his wife's personal injury action. Nevertheless, the vitality of the +Hawkins +rule itself, which was based on an interpretation of statutes defining separate and community property, continued on unimpaired. +1

Two Court of Appeals decisions applied the +Hawkins +rule to the issue before us today, namely, proper characterization of a spouse's third party tort recovery for purposes of distributing it when the marriage has been dissolved. +Perez v. Perez, 11 +Wn. App. 429, 523 P.2d 455 (1974) was a declaratory judgment action brought to determine a woman's interest in a personal injury settlement received by her former husband after their divorce. The injury had occurred during the marriage. Relying on the +Hawkins +rule, the +Perez +court held that the settlement was community property. Since the settlement had not been divided during the divorce action, it was deemed to be property held by the parties as tenants in common. +Perez, +at 431-32.

In re Marriage of Parsons, +28 Wn. App. 276, 622 P.2d +*734 +415, +review denied, +95 Wn.2d 1019 (1981) involved a husband who had received $77,500 in settlement of a personal injury claim. Community medical expenses and lost wages had been otherwise reimbursed. In the subsequent dissolution proceeding, the husband argued that the entire settlement was his separate property, since it compensated him for damages to his personal security, an "asset" brought into the marriage.

The +Parsons +court, believing itself bound by the +Hawkins +line of authority, held the settlement to be community property. It explained the reasoning behind the +Hawkins +rule in modern terms:

Separate property is defined as property and pecuniary rights acquired before marriage or acquired after marriage by gift, bequest, devise or descent. It also includes the rents, issues and profits from separate property. RCW 26.16.010, .020. Community property is all other property acquired by either spouse after marriage that is not acquired or owned as separate property. RCW 26.16-.030. This "waste basket" definition of community property results in property being characterized as community unless it meets the definition of separate property. The Washington rule is that fortuitous acquisition of damages for personal injury by a third party tort-feasor is community property because it does not fit within the definition of separate property.

(Citations omitted.) +Parsons, +at 278.

Ill

The +Hawkins +rule has been criticized by legal commentators and rejected by the majority of our fellow community property states.

Commentators William deFuniak and Michael Vaughn blame the +Hawkins +rule on an incomplete understanding of the basic principles of community property law:

The frequently evident dissatisfaction with the frequently inadequate reasons given for the doctrine that compensation for personal injuries to a spouse is community property lie in an incomplete understanding of the true principles of community property. This incomplete understanding in itself often leads to a too literal inter +*735 +pretation of the local statutes. . . . Except for gifts clearly made to the marital community, community property only consists of that which is acquired by onerous title, that is, by labor or industry of the spouses, or which is acquired in exchange for community property (which, of course, was acquired itself by onerous title, again with the exception as to the gift). It must be plainly evident that a right of action for injuries to person, reputation, property, or the like, or the compensation received therefor, is not property acquired by onerous title. The labor and industry of the spouses did not bring it into being. For that matter, it is not property acquired by lucrative title either. What then, is it? Since the right of action for injury to the person, or for that matter, to the reputation, is intended to bring about compensation for the injury, and the compensation is intended to repair or make whole the injury, so far as is possible in such a case, the compensation partakes of the same character as that which has been injured or suffered loss. In this respect, the situation is very similar to an exchange of property during marriage. But what or who has been injured? Is it the marital community or is it the separate individuality of the spouse? In actuality, both. The physical injury to the spouse, the pain and suffering of the spouse therefrom is an injury to the spouse as an individual. . . . But on the other hand, if the injury deprives the marital community of the earnings or services of the spouse, that is an injury to the marital community; likewise there is loss to the community where the community funds are expended for hospital and medical expenses, etc.

(Footnotes omitted.) W. deFuniak & M. Vaughn, +Community Property +§ 82, at 201-03 (2d ed. 1971). +See also +Cross, +The Community Property Law in Washington, +49 Wash. L. Rev. 729, 773-75 (1974).

Our fellow community property states have also criticized and rejected the +Hawkins +rule. Nevada was the first to do so in +Fredrickson & Watson Constr. Co. v. Boyd, +60 Nev. 117, 102 P.2d 627 (1940). Pursuant to the Nevada community property statutes, all property acquired after marriage and other than by gift, bequest, devise or descent was community property. The +Fredrickson +court acknowledged that +*736 +the statute could be broadly construed to encompass every manner of property acquisition. However, construing the word "acquired" in the light of the uses and purposes of community property, the court concluded that the word encompassed wages or other property acquired through toil, talent, or other productive faculty, but not compensation for personal injury. Rather, a personal injury claim took its character from the right violated, namely, the separate right of personal security. +Fredrickson, +at 121-22.

In +Rogers v. Yellowstone Park Co., +97 Idaho 14, 539 P.2d 566 (1974), the Idaho Supreme Court utilized similar reasoning. There, it was argued that a wife could not sue for personal injuries inflicted through her husband's negligence because, under prior case law, any recovery would be community and benefit the tortfeasor husband. The +Rogers +court acknowledged that prior case law had held tort recovery to be community property because it was "acquired" after marriage, but not by gift, bequest, devise or descent. +Rogers, +at 18. However, it noted, the correct approach was to characterize the recovery in relation to the right violated, +i.e., +the wife's +separate +right to personal security. Thus, it followed that the wife's action was not barred. +2 +Rogers, +at 18-19.

In New Mexico and Arizona, recovery for personal injury suffered by one spouse during the marriage has been held to be community property to the extent it compensates the community for medical expenses and lost wages, but separate to the extent it compensates the injured spouse for his or her pain and suffering. +Soto v. Vandeventer, +56 N.M. 483, 245 P.2d 826 (1952); +Jurek v. Jurek, +124 Ariz. 596, 606 P.2d 812 (1980). In Texas, recovery for personal injury sustained during marriage is the separate property of the injured spouse, except for any recovery for loss of earning +*737 +capacity during the marriage. Tex. Fam. Code Ann. § 5.01(a)(3) (Vernon 1975). Similarly, in Louisiana, damages due to personal injury sustained by a spouse during the marriage are separate property, though damages attributable to community expenses or lost community earnings remain community property. La. Civ. Code Ann. art. 2344 (West Supp. 1983).

Only California has a different rule. There, recovery for personal injury inflicted by a third party is the separate property of the injured spouse only if the cause of action arose while the injured spouse was living separate from the other spouse, or after rendition of a decree of legal separation, an interlocutory decree of dissolution, or a final judgment of dissolution. Cal. Civ. Code § 5126 (West 1983). Otherwise, the rule that personal property acquired during the marriage is community property controls. Cal. Civ. Code § 5110, as amended in 1983 Cal. Legis. Serv. ch. 342 (West).

IV

Upon consideration of these persuasive authorities, we have come to the conclusion that the +Hawkins +rule, based as it was upon a too literal reading of our community property statutes, was wrong from the beginning.

RCW 26.16.030 provides that property "acquired" by either spouse after marriage is community unless it is acquired or owned as prescribed in RCW 26.16.010 and RCW 26.16.020, defining separate property. In company with the Nevada Supreme Court, we believe that the word "acquired" should be construed to encompass wages and other property acquired through the toil, talent, or other productive faculty of either spouse, but not compensation for personal injury. +See Fredrickson & Watson Constr. Co. v. Boyd, +60 Nev. 117, 121, 102 P.2d 627 (1940). Such a construction is consistent with the basic principle that, except for gifts to the community, community property consists only of that which is acquired by onerous title, or in exchange for other community property. W. deFuniak & M. +*738 +Vaughn, at 201.

If recovery for a personal injury suffered during the marriage is not community property under the terms of RCW 26.16.030, how is it to be characterized? Since the recovery is intended to make whole an injury, it should partake of the same character as that which has suffered injury or loss. W. deFuniak & M. Vaughn, at 202. Thus, damages for physical injury and pain and suffering, which compensate the injured spouse for the harm to his or her separate individuality, should be separate property. Damages for injury-related expenses should be community or separate according to which fund incurs the expenses. Similarly, damages for lost wages and diminished earning capacity should partake of the same community or separate character as the wages and earning capacity they are intended to reimburse or make whole.

We note that in most cases, compensation for lost wages and diminished earning capacity will be community property, because the wages which would have been earned during the marriage but for the injury are community. +Colagrossi v. Hendrickson, +50 Wn.2d 266, 272, 310 P.2d 1072 (1957). However, if a marriage is dissolved after the injury is sustained, it may be that the recovery will compensate the injured spouse in part for wages which would have been earned after separation, and would therefore have been separate property pursuant to RCW 26.16.140. Under our holding today, such damages would be separate. Thus, the separated spouse who must receive compensation from a tortfeasor is placed in the same position as a separated spouse who is paid wages by an employer.

It is also true that in most cases, compensation for injury-related expenses will be community property, because the community will incur and pay those expenses. Under our holding today, however, the compensation a divorced spouse receives for continuing injury-related expenses which he or she alone must pay will be separate property. Thus, we eliminate the obvious inequity of permitting the uninjured spouse to share in reimbursement for +*739 +expenses which he or she is not obligated to, and does not, pay.

Turning to the case before us today, we find that the trial judge correctly applied these principles in characterizing Ronna Brown's potential tort recovery. At the time of trial, there were no unreimbursed out-of-pocket expenses. Recovery for out-of-pocket expenses incurred +after +trial was properly held to be the separate property of the party (presumably Ronna) incurring the expenses. Recovery for lost wages and diminished earning capacity was correctly held to be community property up until the date of separation, but the separate property of Ronna thereafter. Finally, recovery for all other damages, +i.e., +pain and suffering, was accurately characterized as Ronna's separate property.

Therefore, we reverse the Court of Appeals and reinstate the judgment of the trial court. +Perez v. Perez, +11 Wn. App. 429, 523 P.2d 455 (1974) and +In re Marriage of Parsons, +28 Wn. App. 276, 622 P.2d 415, +review denied, +95 Wn.2d 1019 (1981) directly conflict with this decision and are hereby disapproved. +Hawkins +and its progeny are overruled to the extent necessary to conform the law to today's opinion.

Williams, C.J., and Rosellini, Stafford, Utter, Brach-tenbach, Dolliver, Dore, and Pearson, JJ., concur.

1

We deviated from the +Hawkins +rule only once. In +Freehe v. Freehe, +81 Wn.2d 183, 191, 500 P.2d 771 (1972), the "established rule that recovery for injuries to a married person by a third-party tort-feasor is community property" was found not controlling in a personal injury action by one spouse against the other. Instead, the injured spouse was permitted to recover as his separate property damages for pain and suffering and one-half the damages for loss of future earnings. Such separate characterization was deemed necessary in order to compensate the injured spouse without unduly benefiting the tortfeasor spouse. +Freehe, +at 191-92.

2

Interestingly, when it came time to determine what damages were recoverable, the +Rogers +court followed +Freehe v. Freehe, supra, +to hold that damages for pain and suffering and one-half lost wages could be recovered as separate property, together with reimbursement of the community's out-of-pocket expenses. +Rogers v. Yellowstone Park Co., +97 Idaho at 20.

Case-law data current through December 31, 2025. Source: CourtListener bulk data.

↑ + \ No newline at end of file diff --git a/.research/brown.txt b/.research/brown.txt new file mode 100644 index 0000000..ac4ea82 --- /dev/null +++ b/.research/brown.txt @@ -0,0 +1 @@ +In Re the Marriage of Brown, 675 P.2d 1207 (Wash. 1984) | HallApproved.com Hall Approved Free Access to American Case Law Statutes Free Legal Archive / Washington / Cases / Washington Supreme Court / 1984 / Washington Supreme Court, 1984 Copy citation Free Legal Archive / Washington / Cases / Washington Supreme Court / 1984 / In Re the Marriage of Brown In Re the Marriage of Brown Washington Supreme Court · Decided January 12, 1984 · Dimmick 675 P.2d 1207; 100 Wash. 2d 729; 1984 Wash. LEXIS 1445 (Pacific Reporter, Second Series) In Re the Marriage of Brown Opinion *730 Dimmick, J. When a third party tortfeasor injures a spouse during the marriage, how should the potential recovery on the personal injury claim be characterized for purposes of distribution in a subsequent dissolution proceeding? The Court of Appeals, Division One, held that Ronna Brown's potential recovery for an injury sustained during her marriage was community property. We reverse. Under our opinion today, recovery for an injury inflicted upon a married person by a third party tortfeasor is the separate property of the injured spouse, except to the extent the recovery compensates the community for lost wages which would have been community property, or injury-related expenses which the community incurred. The disposition of Ronna's potential recovery entered by the trial judge, which was reversed by the Court of Appeals, is in accord with our holding and is reinstated. I Ronna and William L. Brown were married on January 27, 1967. In October 1975, Ronna filed for dissolution. The parties later reconciled and the action was dismissed. Prior to this dismissal, the parties entered into a postnuptial agreement. The agreement provided that certain assets were separate and others were community. It further stated that in the event of dissolution each party would be awarded his or her separate property and all of the community property accumulated by the parties would be equally divided. In September 1979, Ronna instituted a second dissolution action. In this action, both parties agreed that the postnuptial agreement was valid and binding. The trial judge considered herself bound by the agreement and divided the property accordingly. Approximately 6 months before the second action was filed, Ronna had been injured in an automobile accident. At trial, no cross examination concerning her injury or the value of her potential recovery was permitted. Out-of-pocket expenses relating to her injury and incurred prior to *731 trial had been reimbursed in full. The trial court characterized her potential recovery as follows: a. Recovery for out of pocket expenses incurred after trial is the separate property of the party incurring said expenses and should be awarded to that party. b. Recovery for petitioner's lost earnings and diminished earning capacity from the date of the accident until the date of separation, September 4, 1979, is community property and should be awarded one-half to each party. c. Recovery for petitioner's lost earnings and diminished earning capacity after the date of separation, September 4, 1979, is the separate property of the petitioner and should be awarded to her. d. Recovery for all other damages is the separate property of the petitioner and should be awarded to her. The control of the litigation should repose with the petitioner who should have exclusive authority to compromise the claim. In the event the case is submitted to the jury trial the above allocation of the damages should proceed upon special interrogatories. Conclusion of law 6.A.7. Clerk's Papers, at 19-20. William appealed. The Court of Appeals reversed, holding that Ronna's third party tort claim was community property. II The established rule in Washington has heretofore been that recovery for injuries to a married person by a third party tortfeasor is community property. Freehe v. Freehe, 81 Wn.2d 183, 191 , 500 P.2d 771 (1972). This rule has its genesis in the early case of Hawkins v. Front St. Cable Ry., 3 Wash. 592 , 28 P. 1021 (1892). Hawkins was a tort action brought by husband and wife to recover damages resulting from injuries received by the wife while riding as a passenger on a streetcar. The defendant tortfeasor challenged an instruction which permitted the jury to take the husband's loss of his wife's services into consideration in computing damages. This court upheld the instruction on the following reasoning: At common law, when a wife was injured through the tort of a third person, the injury and the right of action *732 were hers, but she could not sue unless her husband, if living, joined her as plaintiff. The recovery in that case was the pecuniary measure of her own injury and suffering in body and mind. But there was another element of damage which could be recovered only by her husband suing alone in a separate action, viz., his loss of her services and his outlay in restoring her to health. . . . . . . But inasmuch as the right to sue for a tort which one has suffered is a chose in action, and therefore property, in those states where, as here, all property acquired by either spouse otherwise than by gift, bequest, devise or descent is common or community property, this chose in action is suable by that member of the community who has the disposition of the community personalty. . . . ... In this case, therefore, the husband was the only necessary party, though the wife, by §7, Code of 1881, is a proper party, and in this action all of the damages naturally flowing from the injury complained of are recoverable. (Italics ours.) Hawkins , at 595-96. Thus, the issue in Hawkins was whether the plaintiff husband could recover damages for the loss of his wife's services in an action brought for personal injury to his wife. The Hawkins court found it necessary to characterize the personal injury claim in order to determine what role the husband played as a plaintiff in the action. Because the claim was community property, it followed that the husband was suing in his capacity as manager of the community personalty, and all damages were recoverable in the one community action. The Hawkins rule that a claim for personal injury to a married person by a third party tortfeasor is community property was consistently followed in subsequent decisions of this court. See, e.g., Chase v. Beard, 55 Wn.2d 58 , 346 P.2d 315 (1959); Ostheller v. Spokane & I.E. R.R., 107 Wash. 678 , 182 P. 630 (1919); Hammond v. Jackson, 89 Wash. 510 , 154 P. 1106 (1916). Although the rule was applied in a variety of contexts, many of the early cases applied it to hold that the husband, as manager of the *733 community personalty, was a necessary party to the wife's action for personal injury sustained during the marriage. See, e.g., Clark v. Beggs, 138 Wash. 62 , 244 P. 121 (1926); Hynes v. Colman Dock Co., 108 Wash. 642 , 185 P. 617 (1919); Schneider v. Biberger, 76 Wash. 504 , 136 P. 701 , 6 A.L.R. 1056 (1913). In 1972, the State Legislature amended the community property statutes to grant the wife equal power to manage and control community property. RCW 26.16.030. This change made Hawkins and its progeny obsolete to the extent they had held that the husband, as manager of the community property, was a necessary party to his wife's personal injury action. Nevertheless, the vitality of the Hawkins rule itself, which was based on an interpretation of statutes defining separate and community property, continued on unimpaired. 1 Two Court of Appeals decisions applied the Hawkins rule to the issue before us today, namely, proper characterization of a spouse's third party tort recovery for purposes of distributing it when the marriage has been dissolved. Perez v. Perez, 11 Wn. App. 429, 523 P.2d 455 (1974) was a declaratory judgment action brought to determine a woman's interest in a personal injury settlement received by her former husband after their divorce. The injury had occurred during the marriage. Relying on the Hawkins rule, the Perez court held that the settlement was community property. Since the settlement had not been divided during the divorce action, it was deemed to be property held by the parties as tenants in common. Perez , at 431-32. In re Marriage of Parsons, 28 Wn. App. 276 , 622 P.2d *734 415, review denied, 95 Wn.2d 1019 (1981) involved a husband who had received $77,500 in settlement of a personal injury claim. Community medical expenses and lost wages had been otherwise reimbursed. In the subsequent dissolution proceeding, the husband argued that the entire settlement was his separate property, since it compensated him for damages to his personal security, an "asset" brought into the marriage. The Parsons court, believing itself bound by the Hawkins line of authority, held the settlement to be community property. It explained the reasoning behind the Hawkins rule in modern terms: Separate property is defined as property and pecuniary rights acquired before marriage or acquired after marriage by gift, bequest, devise or descent. It also includes the rents, issues and profits from separate property. RCW 26.16.010, .020. Community property is all other property acquired by either spouse after marriage that is not acquired or owned as separate property. RCW 26.16-.030. This "waste basket" definition of community property results in property being characterized as community unless it meets the definition of separate property. The Washington rule is that fortuitous acquisition of damages for personal injury by a third party tort-feasor is community property because it does not fit within the definition of separate property. (Citations omitted.) Parsons, at 278. Ill The Hawkins rule has been criticized by legal commentators and rejected by the majority of our fellow community property states. Commentators William deFuniak and Michael Vaughn blame the Hawkins rule on an incomplete understanding of the basic principles of community property law: The frequently evident dissatisfaction with the frequently inadequate reasons given for the doctrine that compensation for personal injuries to a spouse is community property lie in an incomplete understanding of the true principles of community property. This incomplete understanding in itself often leads to a too literal inter *735 pretation of the local statutes. . . . Except for gifts clearly made to the marital community, community property only consists of that which is acquired by onerous title, that is, by labor or industry of the spouses, or which is acquired in exchange for community property (which, of course, was acquired itself by onerous title, again with the exception as to the gift). It must be plainly evident that a right of action for injuries to person, reputation, property, or the like, or the compensation received therefor, is not property acquired by onerous title. The labor and industry of the spouses did not bring it into being. For that matter, it is not property acquired by lucrative title either. What then, is it? Since the right of action for injury to the person, or for that matter, to the reputation, is intended to bring about compensation for the injury, and the compensation is intended to repair or make whole the injury, so far as is possible in such a case, the compensation partakes of the same character as that which has been injured or suffered loss. In this respect, the situation is very similar to an exchange of property during marriage. But what or who has been injured? Is it the marital community or is it the separate individuality of the spouse? In actuality, both. The physical injury to the spouse, the pain and suffering of the spouse therefrom is an injury to the spouse as an individual. . . . But on the other hand, if the injury deprives the marital community of the earnings or services of the spouse, that is an injury to the marital community; likewise there is loss to the community where the community funds are expended for hospital and medical expenses, etc. (Footnotes omitted.) W. deFuniak & M. Vaughn, Community Property § 82, at 201-03 (2d ed. 1971). See also Cross, The Community Property Law in Washington, 49 Wash. L. Rev. 729 , 773-75 (1974). Our fellow community property states have also criticized and rejected the Hawkins rule. Nevada was the first to do so in Fredrickson & Watson Constr. Co. v. Boyd, 60 Nev. 117 , 102 P.2d 627 (1940). Pursuant to the Nevada community property statutes, all property acquired after marriage and other than by gift, bequest, devise or descent was community property. The Fredrickson court acknowledged that *736 the statute could be broadly construed to encompass every manner of property acquisition. However, construing the word "acquired" in the light of the uses and purposes of community property, the court concluded that the word encompassed wages or other property acquired through toil, talent, or other productive faculty, but not compensation for personal injury. Rather, a personal injury claim took its character from the right violated, namely, the separate right of personal security. Fredrickson, at 121-22. In Rogers v. Yellowstone Park Co., 97 Idaho 14 , 539 P.2d 566 (1974), the Idaho Supreme Court utilized similar reasoning. There, it was argued that a wife could not sue for personal injuries inflicted through her husband's negligence because, under prior case law, any recovery would be community and benefit the tortfeasor husband. The Rogers court acknowledged that prior case law had held tort recovery to be community property because it was "acquired" after marriage, but not by gift, bequest, devise or descent. Rogers , at 18. However, it noted, the correct approach was to characterize the recovery in relation to the right violated, i.e., the wife's separate right to personal security. Thus, it followed that the wife's action was not barred. 2 Rogers , at 18-19. In New Mexico and Arizona, recovery for personal injury suffered by one spouse during the marriage has been held to be community property to the extent it compensates the community for medical expenses and lost wages, but separate to the extent it compensates the injured spouse for his or her pain and suffering. Soto v. Vandeventer, 56 N.M. 483 , 245 P.2d 826 (1952); Jurek v. Jurek, 124 Ariz. 596 , 606 P.2d 812 (1980). In Texas, recovery for personal injury sustained during marriage is the separate property of the injured spouse, except for any recovery for loss of earning *737 capacity during the marriage. Tex. Fam. Code Ann. § 5.01 (a)(3) (Vernon 1975). Similarly, in Louisiana, damages due to personal injury sustained by a spouse during the marriage are separate property, though damages attributable to community expenses or lost community earnings remain community property. La. Civ. Code Ann. art. 2344 (West Supp. 1983). Only California has a different rule. There, recovery for personal injury inflicted by a third party is the separate property of the injured spouse only if the cause of action arose while the injured spouse was living separate from the other spouse, or after rendition of a decree of legal separation, an interlocutory decree of dissolution, or a final judgment of dissolution. Cal. Civ. Code § 5126 (West 1983). Otherwise, the rule that personal property acquired during the marriage is community property controls. Cal. Civ. Code § 5110 , as amended in 1983 Cal. Legis. Serv. ch. 342 (West). IV Upon consideration of these persuasive authorities, we have come to the conclusion that the Hawkins rule, based as it was upon a too literal reading of our community property statutes, was wrong from the beginning. RCW 26.16.030 provides that property "acquired" by either spouse after marriage is community unless it is acquired or owned as prescribed in RCW 26.16.010 and RCW 26.16.020, defining separate property. In company with the Nevada Supreme Court, we believe that the word "acquired" should be construed to encompass wages and other property acquired through the toil, talent, or other productive faculty of either spouse, but not compensation for personal injury. See Fredrickson & Watson Constr. Co. v. Boyd, 60 Nev. 117, 121 , 102 P.2d 627 (1940). Such a construction is consistent with the basic principle that, except for gifts to the community, community property consists only of that which is acquired by onerous title, or in exchange for other community property. W. deFuniak & M. *738 Vaughn, at 201. If recovery for a personal injury suffered during the marriage is not community property under the terms of RCW 26.16.030, how is it to be characterized? Since the recovery is intended to make whole an injury, it should partake of the same character as that which has suffered injury or loss. W. deFuniak & M. Vaughn, at 202. Thus, damages for physical injury and pain and suffering, which compensate the injured spouse for the harm to his or her separate individuality, should be separate property. Damages for injury-related expenses should be community or separate according to which fund incurs the expenses. Similarly, damages for lost wages and diminished earning capacity should partake of the same community or separate character as the wages and earning capacity they are intended to reimburse or make whole. We note that in most cases, compensation for lost wages and diminished earning capacity will be community property, because the wages which would have been earned during the marriage but for the injury are community. Colagrossi v. Hendrickson, 50 Wn.2d 266, 272 , 310 P.2d 1072 (1957). However, if a marriage is dissolved after the injury is sustained, it may be that the recovery will compensate the injured spouse in part for wages which would have been earned after separation, and would therefore have been separate property pursuant to RCW 26.16.140. Under our holding today, such damages would be separate. Thus, the separated spouse who must receive compensation from a tortfeasor is placed in the same position as a separated spouse who is paid wages by an employer. It is also true that in most cases, compensation for injury-related expenses will be community property, because the community will incur and pay those expenses. Under our holding today, however, the compensation a divorced spouse receives for continuing injury-related expenses which he or she alone must pay will be separate property. Thus, we eliminate the obvious inequity of permitting the uninjured spouse to share in reimbursement for *739 expenses which he or she is not obligated to, and does not, pay. Turning to the case before us today, we find that the trial judge correctly applied these principles in characterizing Ronna Brown's potential tort recovery. At the time of trial, there were no unreimbursed out-of-pocket expenses. Recovery for out-of-pocket expenses incurred after trial was properly held to be the separate property of the party (presumably Ronna) incurring the expenses. Recovery for lost wages and diminished earning capacity was correctly held to be community property up until the date of separation, but the separate property of Ronna thereafter. Finally, recovery for all other damages, i.e., pain and suffering, was accurately characterized as Ronna's separate property. Therefore, we reverse the Court of Appeals and reinstate the judgment of the trial court. Perez v. Perez, 11 Wn. App. 429 , 523 P.2d 455 (1974) and In re Marriage of Parsons, 28 Wn. App. 276 , 622 P.2d 415 , review denied, 95 Wn.2d 1019 (1981) directly conflict with this decision and are hereby disapproved. Hawkins and its progeny are overruled to the extent necessary to conform the law to today's opinion. Williams, C.J., and Rosellini, Stafford, Utter, Brach-tenbach, Dolliver, Dore, and Pearson, JJ., concur. 1 We deviated from the Hawkins rule only once. In Freehe v. Freehe, 81 Wn.2d 183, 191 , 500 P.2d 771 (1972), the "established rule that recovery for injuries to a married person by a third-party tort-feasor is community property" was found not controlling in a personal injury action by one spouse against the other. Instead, the injured spouse was permitted to recover as his separate property damages for pain and suffering and one-half the damages for loss of future earnings. Such separate characterization was deemed necessary in order to compensate the injured spouse without unduly benefiting the tortfeasor spouse. Freehe , at 191-92. 2 Interestingly, when it came time to determine what damages were recoverable, the Rogers court followed Freehe v. Freehe, supra, to hold that damages for pain and suffering and one-half lost wages could be recovered as separate property, together with reimbursement of the community's out-of-pocket expenses. Rogers v. Yellowstone Park Co., 97 Idaho at 20 . Case-law data current through December 31, 2025. Source: CourtListener bulk data . A public interest project of Aaron Hall, Attorney at Law © 2026 About Federal Minnesota California New York Texas Terms Data from CourtListener / Free Law Project ↑ \ No newline at end of file diff --git a/.research/bulicek.html b/.research/bulicek.html new file mode 100644 index 0000000..789a5c6 --- /dev/null +++ b/.research/bulicek.html @@ -0,0 +1,103 @@ +In the Matter of Marriage of Bulicek, 800 P.2d 394 (Court of Appeals of Washington 1990) | HallApproved.com
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In the Matter of Marriage of Bulicek

In the Matter of Marriage of Bulicek
Court of Appeals of Washington · Decided November 26, 1990 · Baker
800 P.2d 394; 59 Wash. App. 630; 1990 Wash. App. LEXIS 418 +(Pacific Reporter, Second Series)

In the Matter of Marriage of Bulicek

Opinion

Baker, J.

We are asked to review a dissolution decree concerning disposition of retirement benefits and an award of maintenance.

I

George and Janet Bulicek were married in 1963 and separated 22 years later in 1985. A dissolution decree was entered in 1989. At the time of trial, the parties' net earned monthly income was approximately $2,500 for George, and $720 for Janet. Janet also received a monthly disability payment of $169.52. George was in good health. Janet had numerous health problems and was under a doctor's care. George was 52 and Janet was 46 years old at time of trial. The couple had one child who is now an emancipated adult.

At the time of their marriage, George had worked approximately 5 years for GTE in Chicago. When he began work for GTE Northwest in 1969, he received 40 months' +*632 +credit for that work in calculating his GTE Northwest pension. George was offered GTE's Enhanced Early Retirement Program in the fall of 1988, and he could have retired with $1,081.81 per month at the end of 1988. GTE's estimated value of the comparable lump sum distribution of the pension benefit was $130,405.27. George opted not to retire.

In September 1989, George became eligible for normal early retirement, receiving $948.18 per month or a lump sum distribution of approximately $111,000. This would be discounted 3 percent for each year that George is under the age of 55 at his retirement. George may choose normal early retirement anytime between September 1989 and his normal retirement date, April 2002. The trial court characterized the retirement benefits as a partly separate, partly community asset, allocating as separate property benefits earned before marriage and after separation. Out of 275 total accrued months of GTE employment, 185 months were community (67.3 percent) and 90 months were separate (32.7 percent). The court ordered that upon receipt of retirement benefits, the benefits should be divided with an award to Janet as follows:

Total months of 1/2 s Se™*» During Marriage ^ MontUy Benefit Total Months of Accredited Retirement Service at Retirement Date

In other words, Janet would receive 1/2 x 185/275 or 33.65 percent of the monthly retirement benefit.

In addition, the trial court found Janet in need of maintenance and awarded her $500 per month for 1 year and $400 per month thereafter, terminating at her death or upon receipt of her monthly share of the GTE pension benefits.

II

We first consider the issue of maintenance. George contends that the trial court abused its discretion in ordering +*633 +him to pay maintenance until he retires. Janet contends that the trial court considered the statutory factors set forth in RCW 26.09.090 +1 +and acted within its discretion in awarding her $500 per month for 1 year and $400 per month until George retires.

The award of maintenance, like the division of property, is within the discretion of the trial court. +In re Marriage of Nicholson, +17 Wn. App. 110, 561 P.2d 1116 (1977). The only limitation on amount and duration of maintenance under RCW 26.09.090 is that, in light of the relevant factors, the award must be just. +In re Marriage of Morrow, +53 Wn. App. 579, 585, 770 P.2d 197 (1989). Factors listed in RCW 26.09.090 include the financial resources of each party; the duration of the marriage and standard of living during marriage; and the age, physical and emotional condition, and financial obligations of the spouse seeking maintenance, as well as the time needed by the spouse seeking maintenance to acquire education for appropriate employment.

George argues that maintenance should be rehabilitative in nature and transitional in duration, and should last only 1 or 2 years to allow Janet time to secure further job training. The record indicates that rehabilitation is not an issue here. The reality is that Janet does not live on income close +*634 +to the income that supported the couple's standard of living during marriage and will likely never achieve the postdis-solution economic level of George.

Here, after a long-term marriage, Janet is in ill health and has limited job skills and experience. Trial courts are given wide discretion to fashion a dissolution order that will address the circumstances of the parties. Maintenance is one of those discretionary means.

George argues that the maintenance ordered here constitutes a permanent lien on an ex-husband's future income, a result disapproved in +Berg v. Berg, +72 Wn.2d 532, 434 P.2d 1 (1967). The court there quoted from +Hogberg v. Hogberg, +64 Wn.2d 617, 619, 393 P.2d 291 (1964):

Alimony is not a matter of right. When the wife has the ability to earn a living, it is not the policy of the law of this state to give her a perpetual lien on her divorced husband's future income.

(Citations omitted.) +Berg v. Berg, +72 Wn.2d at 533.

While the reasons for this policy include the valid goals of disentangling the divorcing spouses and setting each on a road to self-sufficiency, neither our current statutory language dealing with dissolution nor the known, postdissolution economic realities mandate a blind adherence to the language of the +Berg +court. +2

As the Supreme Court has noted, the spouse's ability for self-support is one factor to be considered under RCW 26.09.090(1)(a). In addition,

[t]he duration of the marriage and the standard of living established during marriage must also be considered, making it clear that maintenance is not just a means of providing bare +*635 +necessities, but rather a flexible tool by which the parties' standard of living may be equalized for an appropriate period of time.

In re Marriage of Washburn, +101 Wn.2d 168, 179, 677 P.2d 152 (1984).

The postdissolution economic position of the parties "is a paramount concern in determining issues of property division and maintenance." +In re Marriage of Morrow, +53 Wn. App. 579, 586, 770 P.2d 197 (1989) (quoting +In re Marriage of Washburn, +101 Wn.2d at 181).

The +Washburn +court dealt with a 10-year marriage and the division of property and an award of maintenance to a party who had put her spouse through professional school. While recognizing that such a party obviously could be financially self-sufficient, maintenance was appropriate to allow the party "to share, temporarily, in the lifestyle which he or she helped the student spouse to attain." +Washburn, +101 Wn.2d at 179.

Similarly, in the instant case we focus on the post-dissolution relative economic positions of the parties. Here, George will be in a position to support a lifestyle more comparable to the lifestyle enjoyed by the couple during marriage than will Janet, given their relative earning powers. The trial court correctly perceived that Janet would be in need of more than temporary support. The court provided a thoughtful resolution of the maintenance and pension issues that allows Janet a continuous stream of income.

Whether the maintenance lasts 1 year or 13 years is George's choice. He is free to retire when he wishes. These parties were married for 26 years. George's income at trial was nearly three times larger than Janet's. Considering the relevant statutory factors, including the predissolution standard of living of the parties and their relative postdis-solution status, it was well within the trial court's discretion to award maintenance to Janet in the +amount and +for the duration provided in its decree.

We hold that the trial court properly considered the statutory factors regarding maintenance and the facts in +*636 +this particular case and did not abuse its discretion in its award of maintenance.

Ill

We next consider the trial court's disposition of pension rights. George contends that the formula adopted by the court improperly allows Janet to share in postseparation contributions to the plan. He argues that the straight percentage formula fails to account for increases in yearly contributions after separation. George asserts that due to his "increasingly greater work experience and expanding earning potential", his earnings and consequently his employer's contributions +3 +for the remainder of his work career will be proportionately much higher than during marriage. The result is that Janet will in effect receive a portion of the postdissolution retirement contributions, which are his separate property. George further contends that the trial court should have given a value to the retirement benefits and apportioned them as of the time of trial, thus avoiding the problem of allowing Janet a share in his separate property.

Pension benefits constitute property rights in the nature of deferred compensation, even if benefits are not presently available. +See Farver v. Department of Retirement Sys., +29 Wn. App. 138, 141, 629 P.2d 903 (1981), +aff'd, +97 Wn.2d 344, 644 P.2d 1149 (1982). In deciding the distribution of property in a dissolution, the trial court has wide discretion. +Wilder v. Wilder, +85 Wn.2d 364, 534 P.2d 1355 (1975). The court seeks a "just and equitable" distribution, considering all relevant factors, including:

(1) The nature and extent of the community property;
(2) The nature and extent of the separate property;
(3) The duration of the marriage; and
(4) The economic circumstances of each spouse at the time the division of property is to become effective, including the desirability of awarding the family home or the right to live therein for reasonable periods to a spouse having custody of any children.

Former RCW 26.09.080.

*637 +Washington courts have in the past sometimes divided pensions on an as-received basis using a percentage formula. In +Edwards v. Edwards, +74 Wn.2d 286, 444 P.2d 703 (1968), the trial court equally divided pension benefits which were currently being received. The Supreme Court upheld the method of allocating the pension but reduced the wife's percentage from 50 percent to 25 percent because her earning power was larger than her husband's. This percentage allocation method, although not used in +DeRevere v. DeRevere, +5 Wn. App. 741, 746, 491 P.2d 249 (1971), was cited by the court as one method of handling allocation of pension rights. The court said:

One method of attempting to resolve the difficulties is to develop a percentage division of the monthly amount of the pension or retirement benefit which will remain constant during the period of time in which the pension is payable. +See Edwards v. Edwards, +74 Wn.2d 286, 444 P.2d 703 (1968). Another method is to award the entire pension to one of the parties, generally the party whose work effort generated the pension, and to award to the other, in lieu of participation in the pension, a sum certain, which may, or may not, be payable over a specified time period.

DeRevere, +5 Wn. App. at 746.

In +In re Marriage of Pea, +17 Wn. App. 728, 566 P.2d 212 (1977), the court computed the wife's community interest in her husband's military pension as follows:

1/2 ^ 13 (years of marriage) ^ MontUy 20 (years of military Income service)

Cf. Wilder v. Wilder, +85 Wn.2d 364, 534 P.2d 1355 (1975) (affirming fixed dollar award of $180 per month to wife from husband's Navy retirement income). The court in +In re Marriage of Pea, supra, +permitted the percentage rate (1/2 x 13/20 = 32.5 percent) to apply to the rate of retirement pay that would be received nearly 3 years after the date of trial, and to apply to any annual or cost of living increases. However, the court did not allow the percentage to "be applied to those increases in the pension due solely +*638 +to service beyond 20 years." +In re Marriage of Pea, +17 Wn. App. at 732.

Several California cases have specifically addressed the method used by the trial court here to divide the pension, as respondent points out in her brief.

In +In re Marriage of Freiberg, +57 Cal. App. 3d 304, 127 Cal. Rptr. 792 (1976), the court dealt with a Navy pension in a 12-year marriage. The husband had 5 years of service before marriage and the pension would vest in 3 years. He argued that retirement benefits should be calculated at the amount fixed at time of separation. The court rejected that argument, stating that the husband and wife were joint owners of the pension rights and entitled to share in increased benefits. The court upheld the trial court's percentage division of monthly retirement benefits. Similarly, in +In re Marriage of Adams, +64 Cal. App. 3d 181, 134 Cal. Rptr. 298 (1976) the court found that the increase in retirement benefits after separation was not due from solely the separate efforts of the husband but was in fact enhanced by the many years of community efforts as well. Thus, the increases were not to be treated as separate property.

In the instant case, George and Janet were married for 22 years before separation. During all that time, George was employed at GTE. His advancements and pay raises during that time came as a direct result of community effort and performance. As in +In re Marriage of Adams, supra, +the prospective increase in retirement benefits due to increased pay after separation is founded on those 22 years of community effort.

We disagree with George's argument that this disposition of pension rights was unjust or inequitable. An award of pension rights on a percentage, as-received basis is to be encouraged. Such a disposition avoids difficult valuation problems, shares the risks inherent in deferred receipt of the income, and provides a source of income to both spouses at a time when there will likely be greater need for it. We acknowledge that George's retirement fund +*639 +may receive proportionately higher future contributions based upon his career longevity and anticipated increases in annual pay. We further acknowledge that the formula utilized for division of future retirement benefits could result in Janet's sharing in those increases. However, far from condemning this apportionment method, we specifically approve it as a means of recognizing the community contribution to such increases.

Appellant argues that +In re Marriage of Pea, supra, +requires a trial court to determine present value of future pension benefits where there is evidence to support such a determination, and prohibits use of a percentage allocation of future benefits on an as-received basis. We reject that analysis. In Washington, the trial court has wide discretion in awarding property in a dissolution. +See In re Marriage of Landry, +103 Wn.2d 807, 699 P.2d 214 (1985). The court in +In re Marriage of Pea, supra, +states that where there is insufficient evidence to determine a present value of a pension plan, the trial court may use the percentage formula. Here, the testimony of the experts varied widely as to the value of the pension. Whether to accept those calculations was within the discretion of the trial court. We decline to rule that a court must determine a present value if any valuation testimony is presented, particularly where, as here, an alternate method provides an equitable solution.

We hold that the trial court did not abuse its discretion in awarding Janet a percentage of the pension on an as-received basis.

IV

Janet contends that $1,000 in attorney's fees is so inadequate as to be an abuse of discretion.

In awarding attorney's fees in a dissolution, the trial court considers the need of the one party and the other party's ability to pay. Neither party is entitled to attorney's fees as a matter of right. +Valley v. Selfridge, +30 Wn. App. 908, 639 P.2d 225 (1982).

*640 +Here, the court had all the facts before it in dividing property, awarding maintenance, and setting attorney's fees. The amount of attorney's fees does appear low given the large disparity in income between the parties. Even after the real property is liquidated and the proceeds split between the parties, Janet's payment of her attorney's fees may leave her in an economically disadvantaged position in comparison with her ex-husband. However, we cannot conclude that the trial court abused its discretion in the award of these attorney's fees and we therefore affirm.

V

As to attorney's fees on appeal, RCW 26.09.140 provides for an award of reasonable attorney's fees for maintaining or defending an action under RCW 26.09. A review of the materials submitted reveals total fees of $6,940 payable by Janet for her attorney's services. We award Janet $6,940 as reasonable attorney's fees. RAP 18.1.

The decision of the trial court is affirmed.

Winsor and Forrest, JJ., concur.

1

The dissolution act of 1973 provided that the factors to be considered by the court in awarding maintenance include:

"(a) The financial resources of the party seeking maintenance, including separate or community property apportioned to him, and his ability to meet his needs independently, including the extent to which a provision for support of a child living with the party includes a sum for that party as custodian;
"(b) The time necessary to acquire sufficient education or training to enable the party seeking maintenance to find employment appropriate to his skill, interests, style of life, and other attendant circumstances;
" (c) The standard of living established during the marriage;
"(d) The duration of the marriage;
" (e) The age, physical and emotional condition, and financial obligations of the spouse seeking maintenance; and
"(f) The ability of the spouse from whom maintenance is sought to meet his needs and financial obligations while meeting those of the spouse seeking maintenance." Former RCW 26.09.090.
2

The reality is "that women still earn approximately 60% of what men do and that traditional female jobs tend to pay less than traditional male jobs." Washington State Bar Ass'n, +Family Law Deskbook +§ 29.5 (1989). Further, in discussing the effects of no-fault and other equality-directed reforms in divorce law, one author noted:

Most judges appear to view the law's goal of equality as a mandate to place an equal burden of support on men and women without regard to the fact that the parties' capacities to support that burden are clearly unequal by virtue of their differing experiences during marriage.

L. Weitzman, +The Divorce Revolution +183 (1985).

3

The retirement plan is totally funded by employer contributions.

Case-law data current through December 31, 2025. Source: CourtListener bulk data.

↑ + \ No newline at end of file diff --git a/.research/bulicek.txt b/.research/bulicek.txt new file mode 100644 index 0000000..e721a23 --- /dev/null +++ b/.research/bulicek.txt @@ -0,0 +1 @@ +In the Matter of Marriage of Bulicek, 800 P.2d 394 (Court of Appeals of Washington 1990) | HallApproved.com Hall Approved Free Access to American Case Law Statutes Free Legal Archive / Washington / Cases / Court of Appeals of Washington / 1990 / Court of Appeals of Washington, 1990 Copy citation Free Legal Archive / Washington / Cases / Court of Appeals of Washington / 1990 / In the Matter of Marriage of Bulicek In the Matter of Marriage of Bulicek Court of Appeals of Washington · Decided November 26, 1990 · Baker 800 P.2d 394; 59 Wash. App. 630; 1990 Wash. App. LEXIS 418 (Pacific Reporter, Second Series) In the Matter of Marriage of Bulicek Opinion Baker, J. We are asked to review a dissolution decree concerning disposition of retirement benefits and an award of maintenance. I George and Janet Bulicek were married in 1963 and separated 22 years later in 1985. A dissolution decree was entered in 1989. At the time of trial, the parties' net earned monthly income was approximately $2,500 for George, and $720 for Janet. Janet also received a monthly disability payment of $169.52. George was in good health. Janet had numerous health problems and was under a doctor's care. George was 52 and Janet was 46 years old at time of trial. The couple had one child who is now an emancipated adult. At the time of their marriage, George had worked approximately 5 years for GTE in Chicago. When he began work for GTE Northwest in 1969, he received 40 months' *632 credit for that work in calculating his GTE Northwest pension. George was offered GTE's Enhanced Early Retirement Program in the fall of 1988, and he could have retired with $1,081.81 per month at the end of 1988. GTE's estimated value of the comparable lump sum distribution of the pension benefit was $130,405.27. George opted not to retire. In September 1989, George became eligible for normal early retirement, receiving $948.18 per month or a lump sum distribution of approximately $111,000. This would be discounted 3 percent for each year that George is under the age of 55 at his retirement. George may choose normal early retirement anytime between September 1989 and his normal retirement date, April 2002. The trial court characterized the retirement benefits as a partly separate, partly community asset, allocating as separate property benefits earned before marriage and after separation. Out of 275 total accrued months of GTE employment, 185 months were community (67.3 percent) and 90 months were separate (32.7 percent). The court ordered that upon receipt of retirement benefits, the benefits should be divided with an award to Janet as follows: Total months of 1/2 s Se™*» During Marriage ^ MontUy Benefit Total Months of Accredited Retirement Service at Retirement Date In other words, Janet would receive 1/2 x 185/275 or 33.65 percent of the monthly retirement benefit. In addition, the trial court found Janet in need of maintenance and awarded her $500 per month for 1 year and $400 per month thereafter, terminating at her death or upon receipt of her monthly share of the GTE pension benefits. II We first consider the issue of maintenance. George contends that the trial court abused its discretion in ordering *633 him to pay maintenance until he retires. Janet contends that the trial court considered the statutory factors set forth in RCW 26.09.090 1 and acted within its discretion in awarding her $500 per month for 1 year and $400 per month until George retires. The award of maintenance, like the division of property, is within the discretion of the trial court. In re Marriage of Nicholson, 17 Wn. App. 110 , 561 P.2d 1116 (1977). The only limitation on amount and duration of maintenance under RCW 26.09.090 is that, in light of the relevant factors, the award must be just. In re Marriage of Morrow, 53 Wn. App. 579, 585 , 770 P.2d 197 (1989). Factors listed in RCW 26.09.090 include the financial resources of each party; the duration of the marriage and standard of living during marriage; and the age, physical and emotional condition, and financial obligations of the spouse seeking maintenance, as well as the time needed by the spouse seeking maintenance to acquire education for appropriate employment. George argues that maintenance should be rehabilitative in nature and transitional in duration, and should last only 1 or 2 years to allow Janet time to secure further job training. The record indicates that rehabilitation is not an issue here. The reality is that Janet does not live on income close *634 to the income that supported the couple's standard of living during marriage and will likely never achieve the postdis-solution economic level of George. Here, after a long-term marriage, Janet is in ill health and has limited job skills and experience. Trial courts are given wide discretion to fashion a dissolution order that will address the circumstances of the parties. Maintenance is one of those discretionary means. George argues that the maintenance ordered here constitutes a permanent lien on an ex-husband's future income, a result disapproved in Berg v. Berg, 72 Wn.2d 532 , 434 P.2d 1 (1967). The court there quoted from Hogberg v. Hogberg, 64 Wn.2d 617, 619 , 393 P.2d 291 (1964): Alimony is not a matter of right. When the wife has the ability to earn a living, it is not the policy of the law of this state to give her a perpetual lien on her divorced husband's future income. (Citations omitted.) Berg v. Berg, 72 Wn.2d at 533 . While the reasons for this policy include the valid goals of disentangling the divorcing spouses and setting each on a road to self-sufficiency, neither our current statutory language dealing with dissolution nor the known, postdissolution economic realities mandate a blind adherence to the language of the Berg court. 2 As the Supreme Court has noted, the spouse's ability for self-support is one factor to be considered under RCW 26.09.090(1)(a). In addition, [t]he duration of the marriage and the standard of living established during marriage must also be considered, making it clear that maintenance is not just a means of providing bare *635 necessities, but rather a flexible tool by which the parties' standard of living may be equalized for an appropriate period of time. In re Marriage of Washburn, 101 Wn.2d 168, 179 , 677 P.2d 152 (1984). The postdissolution economic position of the parties "is a paramount concern in determining issues of property division and maintenance." In re Marriage of Morrow, 53 Wn. App. 579, 586 , 770 P.2d 197 (1989) (quoting In re Marriage of Washburn, 101 Wn.2d at 181 ). The Washburn court dealt with a 10-year marriage and the division of property and an award of maintenance to a party who had put her spouse through professional school. While recognizing that such a party obviously could be financially self-sufficient, maintenance was appropriate to allow the party "to share, temporarily, in the lifestyle which he or she helped the student spouse to attain." Washburn, 101 Wn.2d at 179 . Similarly, in the instant case we focus on the post-dissolution relative economic positions of the parties. Here, George will be in a position to support a lifestyle more comparable to the lifestyle enjoyed by the couple during marriage than will Janet, given their relative earning powers. The trial court correctly perceived that Janet would be in need of more than temporary support. The court provided a thoughtful resolution of the maintenance and pension issues that allows Janet a continuous stream of income. Whether the maintenance lasts 1 year or 13 years is George's choice. He is free to retire when he wishes. These parties were married for 26 years. George's income at trial was nearly three times larger than Janet's. Considering the relevant statutory factors, including the predissolution standard of living of the parties and their relative postdis-solution status, it was well within the trial court's discretion to award maintenance to Janet in the amount and for the duration provided in its decree. We hold that the trial court properly considered the statutory factors regarding maintenance and the facts in *636 this particular case and did not abuse its discretion in its award of maintenance. Ill We next consider the trial court's disposition of pension rights. George contends that the formula adopted by the court improperly allows Janet to share in postseparation contributions to the plan. He argues that the straight percentage formula fails to account for increases in yearly contributions after separation. George asserts that due to his "increasingly greater work experience and expanding earning potential", his earnings and consequently his employer's contributions 3 for the remainder of his work career will be proportionately much higher than during marriage. The result is that Janet will in effect receive a portion of the postdissolution retirement contributions, which are his separate property. George further contends that the trial court should have given a value to the retirement benefits and apportioned them as of the time of trial, thus avoiding the problem of allowing Janet a share in his separate property. Pension benefits constitute property rights in the nature of deferred compensation, even if benefits are not presently available. See Farver v. Department of Retirement Sys., 29 Wn. App. 138, 141 , 629 P.2d 903 (1981), aff'd, 97 Wn.2d 344 , 644 P.2d 1149 (1982). In deciding the distribution of property in a dissolution, the trial court has wide discretion. Wilder v. Wilder, 85 Wn.2d 364 , 534 P.2d 1355 (1975). The court seeks a "just and equitable" distribution, considering all relevant factors, including: (1) The nature and extent of the community property; (2) The nature and extent of the separate property; (3) The duration of the marriage; and (4) The economic circumstances of each spouse at the time the division of property is to become effective, including the desirability of awarding the family home or the right to live therein for reasonable periods to a spouse having custody of any children. Former RCW 26.09.080. *637 Washington courts have in the past sometimes divided pensions on an as-received basis using a percentage formula. In Edwards v. Edwards, 74 Wn.2d 286 , 444 P.2d 703 (1968), the trial court equally divided pension benefits which were currently being received. The Supreme Court upheld the method of allocating the pension but reduced the wife's percentage from 50 percent to 25 percent because her earning power was larger than her husband's. This percentage allocation method, although not used in DeRevere v. DeRevere, 5 Wn. App. 741, 746 , 491 P.2d 249 (1971), was cited by the court as one method of handling allocation of pension rights. The court said: One method of attempting to resolve the difficulties is to develop a percentage division of the monthly amount of the pension or retirement benefit which will remain constant during the period of time in which the pension is payable. See Edwards v. Edwards, 74 Wn.2d 286 , 444 P.2d 703 (1968). Another method is to award the entire pension to one of the parties, generally the party whose work effort generated the pension, and to award to the other, in lieu of participation in the pension, a sum certain, which may, or may not, be payable over a specified time period. DeRevere, 5 Wn. App. at 746 . In In re Marriage of Pea, 17 Wn. App. 728 , 566 P.2d 212 (1977), the court computed the wife's community interest in her husband's military pension as follows: 1/2 ^ 13 (years of marriage) ^ MontUy 20 (years of military Income service) Cf. Wilder v. Wilder, 85 Wn.2d 364 , 534 P.2d 1355 (1975) (affirming fixed dollar award of $180 per month to wife from husband's Navy retirement income). The court in In re Marriage of Pea, supra, permitted the percentage rate (1/2 x 13/20 = 32.5 percent) to apply to the rate of retirement pay that would be received nearly 3 years after the date of trial, and to apply to any annual or cost of living increases. However, the court did not allow the percentage to "be applied to those increases in the pension due solely *638 to service beyond 20 years." In re Marriage of Pea, 17 Wn. App. at 732. Several California cases have specifically addressed the method used by the trial court here to divide the pension, as respondent points out in her brief. In In re Marriage of Freiberg, 57 Cal. App. 3d 304 , 127 Cal. Rptr. 792 (1976), the court dealt with a Navy pension in a 12-year marriage. The husband had 5 years of service before marriage and the pension would vest in 3 years. He argued that retirement benefits should be calculated at the amount fixed at time of separation. The court rejected that argument, stating that the husband and wife were joint owners of the pension rights and entitled to share in increased benefits. The court upheld the trial court's percentage division of monthly retirement benefits. Similarly, in In re Marriage of Adams, 64 Cal. App. 3d 181 , 134 Cal. Rptr. 298 (1976) the court found that the increase in retirement benefits after separation was not due from solely the separate efforts of the husband but was in fact enhanced by the many years of community efforts as well. Thus, the increases were not to be treated as separate property. In the instant case, George and Janet were married for 22 years before separation. During all that time, George was employed at GTE. His advancements and pay raises during that time came as a direct result of community effort and performance. As in In re Marriage of Adams, supra, the prospective increase in retirement benefits due to increased pay after separation is founded on those 22 years of community effort. We disagree with George's argument that this disposition of pension rights was unjust or inequitable. An award of pension rights on a percentage, as-received basis is to be encouraged. Such a disposition avoids difficult valuation problems, shares the risks inherent in deferred receipt of the income, and provides a source of income to both spouses at a time when there will likely be greater need for it. We acknowledge that George's retirement fund *639 may receive proportionately higher future contributions based upon his career longevity and anticipated increases in annual pay. We further acknowledge that the formula utilized for division of future retirement benefits could result in Janet's sharing in those increases. However, far from condemning this apportionment method, we specifically approve it as a means of recognizing the community contribution to such increases. Appellant argues that In re Marriage of Pea, supra, requires a trial court to determine present value of future pension benefits where there is evidence to support such a determination, and prohibits use of a percentage allocation of future benefits on an as-received basis. We reject that analysis. In Washington, the trial court has wide discretion in awarding property in a dissolution. See In re Marriage of Landry, 103 Wn.2d 807 , 699 P.2d 214 (1985). The court in In re Marriage of Pea, supra, states that where there is insufficient evidence to determine a present value of a pension plan, the trial court may use the percentage formula. Here, the testimony of the experts varied widely as to the value of the pension. Whether to accept those calculations was within the discretion of the trial court. We decline to rule that a court must determine a present value if any valuation testimony is presented, particularly where, as here, an alternate method provides an equitable solution. We hold that the trial court did not abuse its discretion in awarding Janet a percentage of the pension on an as-received basis. IV Janet contends that $1,000 in attorney's fees is so inadequate as to be an abuse of discretion. In awarding attorney's fees in a dissolution, the trial court considers the need of the one party and the other party's ability to pay. Neither party is entitled to attorney's fees as a matter of right. Valley v. Selfridge, 30 Wn. App. 908 , 639 P.2d 225 (1982). *640 Here, the court had all the facts before it in dividing property, awarding maintenance, and setting attorney's fees. The amount of attorney's fees does appear low given the large disparity in income between the parties. Even after the real property is liquidated and the proceeds split between the parties, Janet's payment of her attorney's fees may leave her in an economically disadvantaged position in comparison with her ex-husband. However, we cannot conclude that the trial court abused its discretion in the award of these attorney's fees and we therefore affirm. V As to attorney's fees on appeal, RCW 26.09.140 provides for an award of reasonable attorney's fees for maintaining or defending an action under RCW 26.09. A review of the materials submitted reveals total fees of $6,940 payable by Janet for her attorney's services. We award Janet $6,940 as reasonable attorney's fees. RAP 18.1. The decision of the trial court is affirmed. Winsor and Forrest, JJ., concur. 1 The dissolution act of 1973 provided that the factors to be considered by the court in awarding maintenance include: "(a) The financial resources of the party seeking maintenance, including separate or community property apportioned to him, and his ability to meet his needs independently, including the extent to which a provision for support of a child living with the party includes a sum for that party as custodian; "(b) The time necessary to acquire sufficient education or training to enable the party seeking maintenance to find employment appropriate to his skill, interests, style of life, and other attendant circumstances; " (c) The standard of living established during the marriage; "(d) The duration of the marriage; " (e) The age, physical and emotional condition, and financial obligations of the spouse seeking maintenance; and "(f) The ability of the spouse from whom maintenance is sought to meet his needs and financial obligations while meeting those of the spouse seeking maintenance." Former RCW 26.09.090. 2 The reality is "that women still earn approximately 60% of what men do and that traditional female jobs tend to pay less than traditional male jobs." Washington State Bar Ass'n, Family Law Deskbook § 29.5 (1989). Further, in discussing the effects of no-fault and other equality-directed reforms in divorce law, one author noted: Most judges appear to view the law's goal of equality as a mandate to place an equal burden of support on men and women without regard to the fact that the parties' capacities to support that burden are clearly unequal by virtue of their differing experiences during marriage. L. Weitzman, The Divorce Revolution 183 (1985). 3 The retirement plan is totally funded by employer contributions. Case-law data current through December 31, 2025. Source: CourtListener bulk data . A public interest project of Aaron Hall, Attorney at Law © 2026 About Federal Minnesota California New York Texas Terms Data from CourtListener / Free Law Project ↑ \ No newline at end of file diff --git a/.research/cl_ids.json b/.research/cl_ids.json new file mode 100644 index 0000000..c05efd7 --- /dev/null +++ b/.research/cl_ids.json @@ -0,0 +1,155 @@ +{ + "Stachofsky": {}, + "Fleege": { + "1173142": [ + "in-re-the-marriage-of-hall", + "supreme-1984" + ], + "1308125": [ + "in-re-the-marriage-of-washburn", + "supreme-1984" + ] + }, + "Brown": { + "4907477": [ + "in-re-the-marriage-of-brewer", + "supreme-1999" + ], + "4908935": [ + "lunsford-v-saberhagen-holdings-inc", + "supreme-2009" + ], + "1277450": [ + "brewer-v-brewer", + "supreme-1999" + ], + "4909096": [ + "tobin-v-department-of-labor-industries", + "supreme-2010" + ], + "1277389": [ + "in-re-marriage-of-moody", + "supreme-1999" + ], + "4907488": [ + "in-re-the-marriage-of-moody", + "supreme-1999" + ], + "1159146": [ + "matter-of-marriage-of-smith", + "supreme-1983" + ], + "2536991": [ + "lunsford-v-saberhagen-holdings-inc", + "supreme-2009" + ], + "1177136": [ + "in-re-marriage-of-smith", + "supreme-1983" + ], + "1446720": [ + "in-re-the-marriage-of-ortiz", + "supreme-1987" + ], + "2617598": [ + "in-re-the-marriage-of-short", + "supreme-1995" + ], + "1173067": [ + "in-re-the-marriage-of-konzen", + "supreme-1985" + ], + "1262104": [ + "farver-v-department-of-retirement-systems", + "supreme-1982" + ], + "4907587": [ + "allan-v-university-of-washington", + "supreme-2000" + ], + "2205475": [ + "tobin-v-department-of-labor-industries", + "supreme-2010" + ], + "1195370": [ + "allan-v-university-of-washington", + "supreme-2000" + ] + }, + "Washburn": { + "10049041": [ + "in-re-marriage-of-wilcox", + "supreme-2024" + ], + "1282597": [ + "in-re-the-marriage-of-macdonald", + "supreme-1985" + ], + "1173142": [ + "in-re-the-marriage-of-hall", + "supreme-1984" + ] + }, + "Friedlander": {}, + "Short": { + "4907801": [ + "state-v-coria", + "supreme-2002" + ], + "4907246": [ + "seizer-v-sessions", + "supreme-1997" + ], + "10098065": [ + "in-re-marriage-of-porter", + "supreme-2024" + ], + "1172711": [ + "seizer-v-sessions", + "supreme-1997" + ], + "1133457": [ + "in-re-marriage-of-zahm", + "supreme-1999" + ], + "4907495": [ + "in-re-the-marriage-of-zahm", + "supreme-1999" + ], + "4908401": [ + "in-re-the-marriage-of-langham", + "supreme-2005" + ], + "2508486": [ + "in-re-marriage-of-langham", + "supreme-2005" + ], + "2617598": [ + "in-re-the-marriage-of-short", + "supreme-1995" + ], + "4907955": [ + "in-re-the-marriage-of-chumbley", + "supreme-2003" + ], + "2625397": [ + "in-re-marriage-of-chumbley", + "supreme-2003" + ], + "1208247": [ + "connell-v-francisco", + "supreme-1995" + ], + "2602263": [ + "state-v-coria", + "supreme-2002" + ] + }, + "Zahm": {}, + "Luckey": {}, + "Freedman": {}, + "Olivares": {}, + "Sedlock": {}, + "White": {}, + "Rockwell": {} +} \ No newline at end of file diff --git a/.research/dewberry.html b/.research/dewberry.html new file mode 100644 index 0000000..a3d1e1a --- /dev/null +++ b/.research/dewberry.html @@ -0,0 +1,20 @@ +In re the Marriage of DewBerry, 115 Wash. App. 351 (Court of Appeals of Washington 2003) | HallApproved.com
Hall Approved +Free Access to American Case Law
Court of Appeals of Washington, 2003 +

In re the Marriage of DewBerry

In re the Marriage of DewBerry
Court of Appeals of Washington · Decided February 3, 2003 · Coleman
115 Wash. App. 351

In re the Marriage of DewBerry

Opinion of the Court

Coleman, J.

At issue in this dissolution case is whether an oral prenuptial agreement to treat income earned during marriage as separate property is enforceable. Because the trial court found by clear, cogent, and convincing evidence supported by the record that the parties fully performed their separate property agreement during their marriage, we conclude that their oral prenuptial agreement is enforceable. The trial court did not err when it characterized the parties’ property acquired during marriage as separate property in accordance with the agreement. In addition, we conclude that the trial court did not abuse its discretion by allocating the parties’ separate property to the spouse who acquired it. Accordingly, we affirm the trial court’s property division. We also affirm the order of child support.

FACTS

Emanuel George, Jr., and Carla DewBerry started dating in 1980 while they were both living in California. DewBerry had just graduated from Boalt Hall School of Law and was working toward becoming a CPA at Arthur Andersen. George was a college-educated music industry executive.

In 1981, the parties were discussing marriage and George told DewBerry that, because a friend had been wronged in a divorce settlement and lost his house, he insisted on the *356following conditions of marriage: (1) DewBerry would always be fully employed, (2) each party’s income and property would be treated as separate property, (3) each party would own a home to return to if the marriage failed, and (4) DewBerry would not get fat. DewBerry agreed to these conditions. This discussion took place in California, a community property state. Neither party was particularly wealthy at the beginning of their relationship. George and DewBerry married in 1986.

Between 1981 and 2000, George and DewBerry continually affirmed this agreement through words and actions. The record reflects painstaking and meticulous effort to maintain separate finances and property. During their marriage, DewBerry and George deposited their incomes into separate accounts which they used for their personal expenses and investments. In 1990, after the birth of their first child, they opened a joint checking account in order to handle certain agreed household expenses. George and DewBerry deposited a specified amount to the joint account, and they reimbursed their personal accounts from the joint account if they happened to use personal funds for household expenses. They took turns managing that account. By 2000, when George and DewBerry separated, they had accumulated minimal community property in the form of joint accounts and jointly purchased possessions. They held numerous investment, bank, and retirement accounts as individuals, and the spouse who had created and contributed to those accounts was considered the sole owner and manager of the assets in those accounts. The primary beneficiaries of their individual accounts were the parties’ children, or alternatively, the estate of the spouse who funded them.

During their relationship, DewBerry purchased three houses as her separate property, securing financing separately in all instances by signing promissory notes or asking her sister to cosign. The first house that she bought was a duplex in Oakland, which she purchased in 1982 in order to fulfill the third condition of the prenuptial agreement. The *357latter two houses, both located in Seattle, served as the family’s primary residences. In accordance with the parties’ agreement, DewBerry treated these houses as her separate property by paying for maintenance, improvements, and the down payment and mortgage with funds from her separate accounts. George paid DewBerry a set amount each month toward living expenses, such as utilities, and DewBerry repaid George for any maintenance costs he incurred. The only involvement George had with these properties was to sign documents at various times indicating either that he had no interest in the properties (the Oakland duplex and the first family home), or, in the case of the parties’ most recent residence (the Thorndyke house), that he consented to being listed on the purchase documents as husband and wife per the bank’s requirements. There was no intent that George be personally liable, however, for any of the indebtedness on the properties. George already owned real property in Texas and California that he had acquired before their marriage.

In 1985, DewBerry left Arthur Andersen to become an associate in a Seattle law firm. Meanwhile, George worked in sales and marketing in the entertainment and hospitality industries, and his salary was comparable to DewBerry’s initial law firm salary, around $40,000 to $50,000 per year. By the 1990s, however, after DewBerry became a partner at her law firm, her annual salary increased rapidly, totaling over $1 million in 2000. Meanwhile, George’s salary remained constant in the $40,000 to $50,000 range. Both parties worked full-time while sharing parenting responsibilities for their two children.

The trial court entered detailed findings of fact and conclusions of law regarding the parties’ property and oral prenuptial agreement. Specifically, the trial court found by clear, cogent, and convincing evidence that the parties had entered into an oral prenuptial agreement, despite George’s denial of the agreement’s existence. The trial court also found that there had been “complete performance” of that agreement during the parties’ marriage and, thus, the *358parties’ property consisted primarily of separate property. The trial court ordered that the parties’ property be divided roughly in accordance with its status as separate or community property. It awarded DewBerry $2.3 million, or approximately 82 percent of the parties’ property, which consisted almost entirely of real and personal property that DewBerry had acquired during the marriage, as well as her premarriage separate property. George received property worth $600,000, consisting of his real and personal separate property from before and during the marriage, the bulk of the parties’ community property, plus $300,000 cash from DewBerry’s separate accounts. Part of the trial court’s award to George consisted of a cash equivalent of 11 percent of the Thorndyke house value, or $74,250, based upon evidence of some commingling of property interests in the Thorndyke house (i.e., George’s possible liability on the mortgage, his reliance on the house as a primary residence, and traceable community funds used for the down payment).

The trial court also found that George was voluntarily underemployed because he had not worked full-time hours from January 2000 through September 2001, the time of trial. After he was laid off from Eddie Bauer in 1999, George began working the early morning shift from 4 a.m. to 7 a.m. at UPS because it provided steady income and benefits. It also allowed him flexibility to pursue a career as a longshoreman and spend time with his children. The longshoring work was assigned on a daily basis at a dispatch hall, but because George lacked union membership and senior status, he worked only one to two shifts per week. The trial court ordered George to pay child support based upon imputed income of $48,000, which is more than he currently makes in his part-time jobs, but which is less than his salary at Eddie Bauer. George appeals the trial court’s property division and the order of child support.

DECISION

George argues that the trial court erred when it found by clear, cogent, and convincing evidence that an oral separate *359property agreement had been made by the parties prior to marriage and that it had been fully performed during their marriage, making it an enforceable agreement. He claims that such an agreement is void under Washington’s community property laws and the statute of frauds. He also disagrees with the trial court’s conclusion that "almost all of the property the parties own is separate property and it should be awarded to the person who obtained it.” We find no error and affirm.

There is nothing in Washington law that prohibits parties from entering into prenuptial agreements that alter the status of community property. Furthermore, there is substantial evidence to support the trial court’s findings and conclusions regarding the existence and complete performance of the parties’ oral prenuptial agreement. Thus, the part performance exception to the statute of frauds applies and the parties’ oral agreement is enforceable.

Oral separate property agreements made after marriage have consistently been enforced by Washington courts when clear and convincing evidence shows both the existence of the agreement and mutual observance of the agreement. See, e.g., Gage v. Gage, 78 Wash. 262, 138 P. 886 (1914) (holding that wife could pursue her wage claim as her separate property); Union Sec. Co. v. Smith, 93 Wash. 115, 160 P. 304 (1916) (insulating wife’s separate earnings from husband’s creditor); In re Estate of Janssen, 56 Wn.2d 150, 351 P.2d 510 (1960) and Togliatti v. Robertson, 29 Wn.2d 844, 190 P.2d 575 (1948). See also In re Estate of Martin, 127 Wash. 44, 49, 219 P. 838 (1923) (noting enforceability of oral separate property agreements made between spouses).

But Washington courts have not yet addressed a situation where parties have orally agreed prior to marriage to have a separate property agreement during their marriage. Accordingly, this is a matter of first impression, and we address both the statute of frauds and Washington law concerning prenuptial agreements.

*360The statute of frauds requires certain agreements, including agreements made in consideration of marriage, to be in writing. RCW 19.36.010. Failure to put such agreements into writing renders them void. Koontz v. Koontz, 83 Wash. 180, 184-85, 145 P. 201 (1915), reversed on other grounds, In re Estate of Burmeister, 124 Wn.2d 282, 877 P.2d 195 (1994). In Koontz, the husband’s heirs alleged that his surviving spouse had orally agreed prior to marriage that she would not claim any interest in her husband’s estate. Koontz, 83 Wash, at 184-85. The Washington Supreme Court held that any such agreement, if made orally, would violate the statute of frauds and declined to enforce the agreement. Koontz, 83 Wash, at 184-85. The alleged agreement took effect only upon the husband’s death; thus, there was no performance during the parties’ marriage.

The statute of frauds also barred enforcement of an alleged separate property agreement in Graves v. Graves, 48 Wash. 664, 94 P. 481 (1908). In Graves, several years after a husband and wife had divorced, the wife claimed that she was a co-owner of a parcel of real property that was acquired during marriage, but which was not disposed of in the parties’ dissolution decree. The ex-husband contended that he and his ex-wife had entered into an oral agreement to treat each spouse’s property as separate property; thus, he was the sole owner of the parcel in question because he purchased it in his name. The husband conceded, however, that community funds were used to purchase the property, and the court found that the wife had continuously asserted that the property was jointly owned. Thus, the alleged oral prenuptial agreement was void under the statute requiring agreements in consideration of marriage, as well as agreements transferring an interest in real property, to be in writing. Graves, 48 Wash at 667.

DewBerry contends on a number of grounds that the statute of frauds does not apply to the agreement in question here, but the cases she cites do not support her arguments. First, this agreement is not an example of mutual promises made in contemplation of marriage. The *361case DewBerry cites, In re Marriage of Fox, 58 Wn. App. 935, 939, 795 P.2d 1170 (1990), which stated in dicta that “antenuptial agreements made upon mutual promises to marry” do not require a writing, is not on point. Fox, 58 Wn. App. at 939. Although there are mutual promises involved here as there are in any contract, DewBerry and George’s agreement is an agreement made in consideration of marriage. See Koontz, 83 Wash. at 184-86. But for DewBerry and George’s marriage, there would be no reason to have a separate property agreement and, by the terms of George’s conditions, without the agreement, there would have been no marriage. Thus, it is an agreement in consideration of marriage.

Second, DewBerry relies on Brock v. Button, 187 Wash. 27, 59 P.2d 761 (1936) for her argument that a prenuptial agreement that can theoretically be performed within one year does not fall within the statute of frauds. But Brock did not involve a prenuptial agreement. The agreement in Brock, which was held to be unenforceable under the statute of frauds, consisted of mutual promises to marry no earlier than three years after the promises were exchanged. As discussed above, DewBerry’s and George’s agreement does not consist of mutual promises to marry. Here, the writing requirement for agreements made in consideration of marriage applies, regardless of whether the marriage lasts six months or six years. RCW 19.36.010.

Although we hold that the statute of frauds applies to the agreement in question, we conclude that it is enforceable under the part performance exception to the statute of frauds. The doctrine of part performance is an equitable doctrine which provides the remedies of damages or specific performance for agreements that would otherwise be barred by the statute of frauds. See Beckendorf v. Beckendorf, 76 Wn.2d 457, 465, 457 P.2d 603 (1969); Miller v. McCamish, 78 Wn.2d 821, 479 P.2d 919 (1971).

The first requirement of the doctrine of part performance of oral contracts is that the contract must be proved by clear, cogent, and convincing evidence. Granquist *362v. McKean, 29 Wn.2d 440, 445, 187 P.2d 623 (1947). The second requirement is that:

the acts relied upon as constituting part performance must unmistakably point to the existence of the claimed agreement. If they point to some other relationship, such as that of landlord and tenant, or may be accounted for on some other hypothesis, they are not sufficient.

Granquist, 29 Wn.2d at 445. Where the evidentiary standard is clear, cogent, and convincing, the appellate court must determine whether the substantial evidence in support of the findings of fact is “highly probable.” In re Marriage of Schweitzer, 132 Wn.2d 318, 329, 937 P.2d 1062 (1997).

George contends that the trial court’s findings are not supported by clear, cogent, and convincing evidence, but his argument is based solely on his perception that the trial court erred in finding that DewBerry’s testimony regarding the creation of the agreement was more credible. The trial court’s credibility findings are not subject to review on appeal. In re Marriage of Fiorito, 112 Wn. App. 657, 667, 50 P.3d 298 (2002). Here, the terms of the agreement were clear and simple. Several witnesses testified that the parties created an oral prenuptial agreement and that George and DewBerry acted in accordance with that agreement. Furthermore, despite George’s denial of the agreement, the steps taken by the parties to avoid commingling of their assets were unusually strong evidence of a separate property agreement. It was undisputed that the parties meticulously accounted for and handled their individual incomes as separate property and created minimal joint accounts to handle certain family-related expenses and requirements. The husband and wife relationship cannot account for such painstaking efforts to establish and maintain separate property. We conclude that the trial court’s determination that an oral agreement was made is supported by substantial evidence that is “highly probable.”

George also contends that there was no finding of complete performance to take the agreement out of the *363statute of frauds. This contention lacks merit, as the trial court expressly stated in its oral opinion that it found complete performance:

So, then, looking at whether or not under Washington law the oral contract can be enforced, we have to look then at the exceptions that will allow for an enforcement for such a contract. Performance is certainly one of them. I find that there was really complete performance at least up to the present. I won’t go back though all of the factors that I listed, but the parties did clearly keep their property separate.

The oral opinion is expressly integrated into the written findings of fact and conclusions of law. Thus, the trial court’s decision to enforce the oral prenuptial agreement was based upon a recognized exception to the statute of frauds and is supported by the proper evidentiary standard.

Although Washington has never enforced an oral prenuptial agreement, several other jurisdictions have. O’Shea v. O’Shea, 221 So. 2d 223, 226 (Fla. Dist. Ct. App. 1969); In re Marriage of Lemoine-Hofmann, 827 P.2d 587 (Colo. Ct. App. 1992); Hall v. Hall, 222 Cal. App. 3d 578, 586, 271 Cal. Rptr. 773, 778 (1990). These cases all involved partial or full performance of an oral prenuptial agreement. The case at bar is similar to the ones cited above because each of those cases involved complete performance of an oral prenuptial agreement during the parties’ marriages. Koontz and Graves are distinguishable because there was no performance of the alleged oral agreement.

We also reject George’s contention that the oral prenuptial agreement is void because it is against public policy favoring creation of community property. Under Washington law, there is a presumption that all income earned during marriage will be community property. RCW 26.16.030. This presumption may be rebutted by entering into a separate property agreement, but proof of such an agreement is held to a higher evidentiary standard than a community property agreement. Ryan v. Diafos, 110 Wn. App. 758, 37 P.3d 304 (2001); Kolmorgan v. Schaller, 51 Wn.2d 94, 99, 316 P.2d 111 (1957).

*364George argues that Washington law prohibits parties from entering into an agreement to repudiate the community property system and that such an agreement is void because it conflicts with public policy favoring creation of community property. This is not an accurate statement of Washington law. Washington courts have long held that a husband and wife may contractually modify the status of their property. See Hamlin v. Merlino, 44 Wn.2d 851, 864, 272 P.2d 125 (1954); State v. Miller, 32 Wn.2d 149, 158, 201 P.2d 136 (1948). Public policy favors prenuptial agreements because they are “generally regarded as conducive to marital tranquility and the avoidance of disputes about property in the future.” Friedlander v. Friedlander, 80 Wn.2d 293, 301, 494 P.2d 208 (1972). Prenuptial agreements are contracts subject to the principles of contract law. In re Marriage of Burke, 96 Wn. App. 474, 477, 980 P.2d 265 (1999).

Washington courts evaluate prenuptial agreements under the Matson two-prong test to determine whether the contract is substantively and procedurally fair. In re Marriage of Matson, 107 Wn.2d 479, 730 P.2d 668 (1986). “If fair and fairly made, we have held prenuptial agreements between competent parties to be valid and binding.” Matson, 107 Wn.2d at 482. The first prong of Matson asks whether the agreement made a fair and reasonable provision for the spouse not seeking enforcement. If the answer is yes, the agreement is valid. If the answer is no, the second prong asks whether there was full disclosure of the value and nature of the property involved and whether there was full knowledge and independent advice about each spouse’s rights. When an oral prenuptial agreement does not purport to waive a spouse’s right to an equitable distribution of marital property, Matson does not apply. Matson, 107 Wn.2d at 482.

Here, the terms of the parties’ agreement were clear and straightforward. There was no provision of that agreement, however, that directed the trial court to dispose of the parties’ property in any particular manner upon dissolution or purported to waive a spouse’s interest to an equitable

*365distribution of property. Accordingly, it is an agreement that falls outside of Matson. Nevertheless, even if we were to evaluate the agreement for fairness, as the trial court did, we agree with the trial court that the prenuptial agreement satisfies the Matson test. Under the agreement, each party was able to and did accumulate substantial separate property. Cf. Matson, 107 Wn.2d at 486 (agreement voided because it prevented wife from accumulating her own separate property or making any claim against her husband’s separate property, to which husband devoted substantial time and energy during marriage); In re Marriage of Foran, 67 Wn App. 242, 248, 834 P.2d 1081 (1992). There is nothing unfair about two well-educated working professionals agreeing to preserve the fruits of their labor for their individual benefit. Indeed, as the one requesting the agreement, George apparently assumed that he had greater financial security, since he already owned some real estate and had a good job. Although in hindsight George may have been mistaken, this does not change the court’s analysis. Both parties were aware of each other’s education, assets, and income potential and had ample time to consider the agreement during their 5-year engagement and 14-year marriage. We conclude that the agreement was both procedurally and substantively fair to both parties.

George’s next contention is that the trial court erred by “failing to make a fair and equitable property division,” as required by RCW 26.09.080. The record shows, however, that all of the parties’ separate and community property was before the court, which did exercise its discretion to make an equitable division of property.1 Therefore, we do *366not address George’s argument that a trial court is always required to comply with RCW 26.09.080, even if a valid prenuptial agreement provides a different disposition. As we have already concluded, the agreement at issue here did not bind the parties to any division of property upon dissolution. The trial court properly considered the parties’ prenuptial agreement and the RCW 26.09.080 factors in making its distribution.

Moreover, “[t]he trial court has broad discretion in awarding property in a dissolution action, and will be reversed only upon a showing of manifest abuse of discretion.” In re Marriage of Fiorito, 112 Wn. App. 657, 667-68, 50 P.3d 298 (2002). Just and equitable distribution does not mean that the court must make an equal distribution. Friedlander, 80 Wn.2d at 305. In a well-reasoned oral opinion, the trial court fully set forth tenable grounds for dividing the parties’ property in accordance with the parties’ prenuptial agreement. The court’s disposition relied in part on the fact that each party accumulated substantial separate property during the marriage and both parties are capable of working full-time and continuing to accumulate and manage their assets. Based upon the parties’ agreement and expectations under that agreement, it cannot be said that the trial court’s property distribution was an abuse of discretion.

Lastly, we address George’s contention that the trial court erred when it imputed income of $48,000 to him even though he now earns less money in his two part-time jobs for UPS and as a longshoreman. George claims that his part-time jobs constitute full-time employment and that the trial court could not have imputed income if he were *367working full-time. He also claims that he cannot earn $48,000 per year without changing jobs or working in excess of 40 hours; thus, the amount of income imputed was an abuse of the court’s discretion. Neither claim has merit.

An award of child support is reviewed for an abuse of discretion. In re Marriage of Curran, 26 Wn. App. 108, 110, 611 P.2d 1350 (1980). Under RCW 26.19.071(6), the trial court must impute income to a parent who is voluntarily underemployed. The court first determines whether or not a parent is voluntarily underemployed based upon the parent’s work history, education, health, age, and other relevant factors. In re Marriage of Peterson, 80 Wn. App. 148, 153, 906 P.2d 1009 (1995). “If a parent is underemployed but also ‘gainfully employed on a full-time basis,’ the court must make a further determination as to whether the parent is ‘purposely underemployed to reduce the parent’s child support obligation.’ ” Peterson, 80 Wn. App. at 153 (quoting RCW 26.19.071(6)). The court may not impute income to a parent who is gainfully employed full-time unless the court finds that the parent is voluntarily underemployed and is purposefully underemployed to reduce the parent’s child support obligation. RCW 26.19-.071(6).

The trial court found that George was voluntarily underemployed and imputed income at a level of $48,000 per year for the purposes of child support. The facts pertinent to the court’s determination were that George is a healthy, 47-year-old college graduate with a history of executive-type sales and marketing jobs. In late 1999, George lost a job where he earned $55,000 per year. George testified that he started working 20 hours per week at $10 per hour at United Parcel Service in January 2000 because it provided good benefits for part-time work. This job gave him the flexible schedule required for him to work toward the requirements for a new career as a longshoreman. George does not argue that he is unemployable, and all of the evidence indicates that his underemployment has been brought about by his own free choice. See In re Marriage of

*368Brockopp, 78 Wn. App. 441, 446 n.5, 898 P.2d 849 (1995). While there was no suggestion that George is trying to lower his income to avoid child support, the trial court’s determinations that George is not employed full-time and is voluntarily underemployed are supported by the record.

We also reject George’s argument that it was improper to impute his income at a level higher than he could earn from 40 hours of longshore work. In Peterson, we held that it was an abuse of discretion to impute income based upon national averages after the trial court found that the full-time work with below average salary was consistent with the parent’s work history. Peterson, 80 Wn. App. at 154. Basing George’s imputed income on the salary levels he maintained during the 1990s was reasonable and appropriate under RCW 26.19.071(6).

George has requested an award of his attorney fees on appeal pursuant to RCW 26.09.140. Based upon the record, it appears that both parties have sufficient financial resources to pay their own attorney fees. Accordingly, we decline his request.

We affirm.

Cox, A.C.J., and Grosse, J., concur.

Reconsideration denied March 5, 2003.

Review denied at 150 Wn.2d 1006 (2003).

The trial court awarded $300,000 of DewBerry’s separate property to George to balance the property distribution, stating:

Then the real question for me is: Does equity require or suggest that more should be distributed because of the disparity of their incomes at this time, and because of the length of the marriage, which is, I guess, of moderate length? I do think that, given the good fortunes and the bad fortunes that have evolved on these parties, that Ms. DewBerry herself recognized that equity may require more. She has offered $300,000. I would say that it is difficult to judge these things, but it would seem to me that her ability to earn the kind of monies that she has made in the last several years has been assisted by Mr. George’s *366parenting. I think it is clear that it is harder as a single parent to both work to your full capacity and also meet your parenting responsibilities, and she recognizes this by her testimony that she may have to cut back her hours to spend more time with the children.
I do feel that further equitable distribution is appropriate and I will adopt the figure of $300,000 that she proposed.
An additional $300,000 cash is an equity distribution from her separate property.

Case-law data current through December 31, 2025. Source: CourtListener bulk data.

↑ + \ No newline at end of file diff --git a/.research/dewberry.txt b/.research/dewberry.txt new file mode 100644 index 0000000..bd896c0 --- /dev/null +++ b/.research/dewberry.txt @@ -0,0 +1 @@ +In re the Marriage of DewBerry, 115 Wash. App. 351 (Court of Appeals of Washington 2003) | HallApproved.com Hall Approved Free Access to American Case Law Statutes Free Legal Archive / Washington / Cases / Court of Appeals of Washington / 2003 / Court of Appeals of Washington, 2003 Copy citation Free Legal Archive / Washington / Cases / Court of Appeals of Washington / 2003 / In re the Marriage of DewBerry In re the Marriage of DewBerry Court of Appeals of Washington · Decided February 3, 2003 · Coleman 115 Wash. App. 351 In re the Marriage of DewBerry Opinion of the Court Coleman, J. At issue in this dissolution case is whether an oral prenuptial agreement to treat income earned during marriage as separate property is enforceable. Because the trial court found by clear, cogent, and convincing evidence supported by the record that the parties fully performed their separate property agreement during their marriage, we conclude that their oral prenuptial agreement is enforceable. The trial court did not err when it characterized the parties’ property acquired during marriage as separate property in accordance with the agreement. In addition, we conclude that the trial court did not abuse its discretion by allocating the parties’ separate property to the spouse who acquired it. Accordingly, we affirm the trial court’s property division. We also affirm the order of child support. FACTS Emanuel George, Jr., and Carla DewBerry started dating in 1980 while they were both living in California. DewBerry had just graduated from Boalt Hall School of Law and was working toward becoming a CPA at Arthur Andersen. George was a college-educated music industry executive. In 1981, the parties were discussing marriage and George told DewBerry that, because a friend had been wronged in a divorce settlement and lost his house, he insisted on the *356 following conditions of marriage: (1) DewBerry would always be fully employed, (2) each party’s income and property would be treated as separate property, (3) each party would own a home to return to if the marriage failed, and (4) DewBerry would not get fat. DewBerry agreed to these conditions. This discussion took place in California, a community property state. Neither party was particularly wealthy at the beginning of their relationship. George and DewBerry married in 1986. Between 1981 and 2000, George and DewBerry continually affirmed this agreement through words and actions. The record reflects painstaking and meticulous effort to maintain separate finances and property. During their marriage, DewBerry and George deposited their incomes into separate accounts which they used for their personal expenses and investments. In 1990, after the birth of their first child, they opened a joint checking account in order to handle certain agreed household expenses. George and DewBerry deposited a specified amount to the joint account, and they reimbursed their personal accounts from the joint account if they happened to use personal funds for household expenses. They took turns managing that account. By 2000, when George and DewBerry separated, they had accumulated minimal community property in the form of joint accounts and jointly purchased possessions. They held numerous investment, bank, and retirement accounts as individuals, and the spouse who had created and contributed to those accounts was considered the sole owner and manager of the assets in those accounts. The primary beneficiaries of their individual accounts were the parties’ children, or alternatively, the estate of the spouse who funded them. During their relationship, DewBerry purchased three houses as her separate property, securing financing separately in all instances by signing promissory notes or asking her sister to cosign. The first house that she bought was a duplex in Oakland, which she purchased in 1982 in order to fulfill the third condition of the prenuptial agreement. The *357 latter two houses, both located in Seattle, served as the family’s primary residences. In accordance with the parties’ agreement, DewBerry treated these houses as her separate property by paying for maintenance, improvements, and the down payment and mortgage with funds from her separate accounts. George paid DewBerry a set amount each month toward living expenses, such as utilities, and DewBerry repaid George for any maintenance costs he incurred. The only involvement George had with these properties was to sign documents at various times indicating either that he had no interest in the properties (the Oakland duplex and the first family home), or, in the case of the parties’ most recent residence (the Thorndyke house), that he consented to being listed on the purchase documents as husband and wife per the bank’s requirements. There was no intent that George be personally liable, however, for any of the indebtedness on the properties. George already owned real property in Texas and California that he had acquired before their marriage. In 1985, DewBerry left Arthur Andersen to become an associate in a Seattle law firm. Meanwhile, George worked in sales and marketing in the entertainment and hospitality industries, and his salary was comparable to DewBerry’s initial law firm salary, around $40,000 to $50,000 per year. By the 1990s, however, after DewBerry became a partner at her law firm, her annual salary increased rapidly, totaling over $1 million in 2000. Meanwhile, George’s salary remained constant in the $40,000 to $50,000 range. Both parties worked full-time while sharing parenting responsibilities for their two children. The trial court entered detailed findings of fact and conclusions of law regarding the parties’ property and oral prenuptial agreement. Specifically, the trial court found by clear, cogent, and convincing evidence that the parties had entered into an oral prenuptial agreement, despite George’s denial of the agreement’s existence. The trial court also found that there had been “complete performance” of that agreement during the parties’ marriage and, thus, the *358 parties’ property consisted primarily of separate property. The trial court ordered that the parties’ property be divided roughly in accordance with its status as separate or community property. It awarded DewBerry $2.3 million, or approximately 82 percent of the parties’ property, which consisted almost entirely of real and personal property that DewBerry had acquired during the marriage, as well as her premarriage separate property. George received property worth $600,000, consisting of his real and personal separate property from before and during the marriage, the bulk of the parties’ community property, plus $300,000 cash from DewBerry’s separate accounts. Part of the trial court’s award to George consisted of a cash equivalent of 11 percent of the Thorndyke house value, or $74,250, based upon evidence of some commingling of property interests in the Thorndyke house (i.e., George’s possible liability on the mortgage, his reliance on the house as a primary residence, and traceable community funds used for the down payment). The trial court also found that George was voluntarily underemployed because he had not worked full-time hours from January 2000 through September 2001, the time of trial. After he was laid off from Eddie Bauer in 1999, George began working the early morning shift from 4 a.m. to 7 a.m. at UPS because it provided steady income and benefits. It also allowed him flexibility to pursue a career as a longshoreman and spend time with his children. The longshoring work was assigned on a daily basis at a dispatch hall, but because George lacked union membership and senior status, he worked only one to two shifts per week. The trial court ordered George to pay child support based upon imputed income of $48,000, which is more than he currently makes in his part-time jobs, but which is less than his salary at Eddie Bauer. George appeals the trial court’s property division and the order of child support. DECISION George argues that the trial court erred when it found by clear, cogent, and convincing evidence that an oral separate *359 property agreement had been made by the parties prior to marriage and that it had been fully performed during their marriage, making it an enforceable agreement. He claims that such an agreement is void under Washington’s community property laws and the statute of frauds. He also disagrees with the trial court’s conclusion that "almost all of the property the parties own is separate property and it should be awarded to the person who obtained it.” We find no error and affirm. There is nothing in Washington law that prohibits parties from entering into prenuptial agreements that alter the status of community property. Furthermore, there is substantial evidence to support the trial court’s findings and conclusions regarding the existence and complete performance of the parties’ oral prenuptial agreement. Thus, the part performance exception to the statute of frauds applies and the parties’ oral agreement is enforceable. Oral separate property agreements made after marriage have consistently been enforced by Washington courts when clear and convincing evidence shows both the existence of the agreement and mutual observance of the agreement. See, e.g., Gage v. Gage, 78 Wash. 262 , 138 P. 886 (1914) (holding that wife could pursue her wage claim as her separate property); Union Sec. Co. v. Smith, 93 Wash. 115 , 160 P. 304 (1916) (insulating wife’s separate earnings from husband’s creditor); In re Estate of Janssen, 56 Wn.2d 150 , 351 P.2d 510 (1960) and Togliatti v. Robertson, 29 Wn.2d 844 , 190 P.2d 575 (1948). See also In re Estate of Martin, 127 Wash. 44, 49 , 219 P. 838 (1923) (noting enforceability of oral separate property agreements made between spouses). But Washington courts have not yet addressed a situation where parties have orally agreed prior to marriage to have a separate property agreement during their marriage. Accordingly, this is a matter of first impression, and we address both the statute of frauds and Washington law concerning prenuptial agreements. *360 The statute of frauds requires certain agreements, including agreements made in consideration of marriage, to be in writing. RCW 19.36.010. Failure to put such agreements into writing renders them void. Koontz v. Koontz, 83 Wash. 180, 184-85 , 145 P. 201 (1915), reversed on other grounds, In re Estate of Burmeister, 124 Wn.2d 282 , 877 P.2d 195 (1994). In Koontz , the husband’s heirs alleged that his surviving spouse had orally agreed prior to marriage that she would not claim any interest in her husband’s estate. Koontz , 83 Wash, at 184-85. The Washington Supreme Court held that any such agreement, if made orally, would violate the statute of frauds and declined to enforce the agreement. Koontz , 83 Wash, at 184-85. The alleged agreement took effect only upon the husband’s death; thus, there was no performance during the parties’ marriage. The statute of frauds also barred enforcement of an alleged separate property agreement in Graves v. Graves, 48 Wash. 664 , 94 P. 481 (1908). In Graves , several years after a husband and wife had divorced, the wife claimed that she was a co-owner of a parcel of real property that was acquired during marriage, but which was not disposed of in the parties’ dissolution decree. The ex-husband contended that he and his ex-wife had entered into an oral agreement to treat each spouse’s property as separate property; thus, he was the sole owner of the parcel in question because he purchased it in his name. The husband conceded, however, that community funds were used to purchase the property, and the court found that the wife had continuously asserted that the property was jointly owned. Thus, the alleged oral prenuptial agreement was void under the statute requiring agreements in consideration of marriage, as well as agreements transferring an interest in real property, to be in writing. Graves , 48 Wash at 667. DewBerry contends on a number of grounds that the statute of frauds does not apply to the agreement in question here, but the cases she cites do not support her arguments. First, this agreement is not an example of mutual promises made in contemplation of marriage. The *361 case DewBerry cites, In re Marriage of Fox, 58 Wn. App. 935, 939 , 795 P.2d 1170 (1990), which stated in dicta that “antenuptial agreements made upon mutual promises to marry” do not require a writing, is not on point. Fox, 58 Wn. App. at 939 . Although there are mutual promises involved here as there are in any contract, DewBerry and George’s agreement is an agreement made in consideration of marriage. See Koontz, 83 Wash. at 184-86 . But for DewBerry and George’s marriage, there would be no reason to have a separate property agreement and, by the terms of George’s conditions, without the agreement, there would have been no marriage. Thus, it is an agreement in consideration of marriage. Second, DewBerry relies on Brock v. Button, 187 Wash. 27 , 59 P.2d 761 (1936) for her argument that a prenuptial agreement that can theoretically be performed within one year does not fall within the statute of frauds. But Brock did not involve a prenuptial agreement. The agreement in Brock , which was held to be unenforceable under the statute of frauds, consisted of mutual promises to marry no earlier than three years after the promises were exchanged. As discussed above, DewBerry’s and George’s agreement does not consist of mutual promises to marry. Here, the writing requirement for agreements made in consideration of marriage applies, regardless of whether the marriage lasts six months or six years. RCW 19.36.010. Although we hold that the statute of frauds applies to the agreement in question, we conclude that it is enforceable under the part performance exception to the statute of frauds. The doctrine of part performance is an equitable doctrine which provides the remedies of damages or specific performance for agreements that would otherwise be barred by the statute of frauds. See Beckendorf v. Beckendorf, 76 Wn.2d 457, 465 , 457 P.2d 603 (1969); Miller v. McCamish, 78 Wn.2d 821 , 479 P.2d 919 (1971). The first requirement of the doctrine of part performance of oral contracts is that the contract must be proved by clear, cogent, and convincing evidence. Granquist *362 v. McKean, 29 Wn.2d 440, 445 , 187 P.2d 623 (1947). The second requirement is that: the acts relied upon as constituting part performance must unmistakably point to the existence of the claimed agreement. If they point to some other relationship, such as that of landlord and tenant, or may be accounted for on some other hypothesis, they are not sufficient. Granquist, 29 Wn.2d at 445 . Where the evidentiary standard is clear, cogent, and convincing, the appellate court must determine whether the substantial evidence in support of the findings of fact is “highly probable.” In re Marriage of Schweitzer, 132 Wn.2d 318, 329 , 937 P.2d 1062 (1997). George contends that the trial court’s findings are not supported by clear, cogent, and convincing evidence, but his argument is based solely on his perception that the trial court erred in finding that DewBerry’s testimony regarding the creation of the agreement was more credible. The trial court’s credibility findings are not subject to review on appeal. In re Marriage of Fiorito, 112 Wn. App. 657, 667 , 50 P.3d 298 (2002). Here, the terms of the agreement were clear and simple. Several witnesses testified that the parties created an oral prenuptial agreement and that George and DewBerry acted in accordance with that agreement. Furthermore, despite George’s denial of the agreement, the steps taken by the parties to avoid commingling of their assets were unusually strong evidence of a separate property agreement. It was undisputed that the parties meticulously accounted for and handled their individual incomes as separate property and created minimal joint accounts to handle certain family-related expenses and requirements. The husband and wife relationship cannot account for such painstaking efforts to establish and maintain separate property. We conclude that the trial court’s determination that an oral agreement was made is supported by substantial evidence that is “highly probable.” George also contends that there was no finding of complete performance to take the agreement out of the *363 statute of frauds. This contention lacks merit, as the trial court expressly stated in its oral opinion that it found complete performance: So, then, looking at whether or not under Washington law the oral contract can be enforced, we have to look then at the exceptions that will allow for an enforcement for such a contract. Performance is certainly one of them. I find that there was really complete performance at least up to the present. I won’t go back though all of the factors that I listed, but the parties did clearly keep their property separate. The oral opinion is expressly integrated into the written findings of fact and conclusions of law. Thus, the trial court’s decision to enforce the oral prenuptial agreement was based upon a recognized exception to the statute of frauds and is supported by the proper evidentiary standard. Although Washington has never enforced an oral prenuptial agreement, several other jurisdictions have. O’Shea v. O’Shea, 221 So. 2d 223, 226 (Fla. Dist. Ct. App. 1969); In re Marriage of Lemoine-Hofmann, 827 P.2d 587 (Colo. Ct. App. 1992); Hall v. Hall, 222 Cal. App. 3d 578, 586 , 271 Cal. Rptr. 773, 778 (1990). These cases all involved partial or full performance of an oral prenuptial agreement. The case at bar is similar to the ones cited above because each of those cases involved complete performance of an oral prenuptial agreement during the parties’ marriages. Koontz and Graves are distinguishable because there was no performance of the alleged oral agreement. We also reject George’s contention that the oral prenuptial agreement is void because it is against public policy favoring creation of community property. Under Washington law, there is a presumption that all income earned during marriage will be community property. RCW 26.16.030. This presumption may be rebutted by entering into a separate property agreement, but proof of such an agreement is held to a higher evidentiary standard than a community property agreement. Ryan v. Diafos, 110 Wn. App. 758 , 37 P.3d 304 (2001); Kolmorgan v. Schaller, 51 Wn.2d 94, 99 , 316 P.2d 111 (1957). *364 George argues that Washington law prohibits parties from entering into an agreement to repudiate the community property system and that such an agreement is void because it conflicts with public policy favoring creation of community property. This is not an accurate statement of Washington law. Washington courts have long held that a husband and wife may contractually modify the status of their property. See Hamlin v. Merlino, 44 Wn.2d 851, 864 , 272 P.2d 125 (1954); State v. Miller, 32 Wn.2d 149, 158 , 201 P.2d 136 (1948). Public policy favors prenuptial agreements because they are “generally regarded as conducive to marital tranquility and the avoidance of disputes about property in the future.” Friedlander v. Friedlander, 80 Wn.2d 293, 301 , 494 P.2d 208 (1972). Prenuptial agreements are contracts subject to the principles of contract law. In re Marriage of Burke, 96 Wn. App. 474, 477 , 980 P.2d 265 (1999). Washington courts evaluate prenuptial agreements under the Matson two-prong test to determine whether the contract is substantively and procedurally fair. In re Marriage of Matson, 107 Wn.2d 479 , 730 P.2d 668 (1986). “If fair and fairly made, we have held prenuptial agreements between competent parties to be valid and binding.” Matson, 107 Wn.2d at 482 . The first prong of Matson asks whether the agreement made a fair and reasonable provision for the spouse not seeking enforcement. If the answer is yes, the agreement is valid. If the answer is no, the second prong asks whether there was full disclosure of the value and nature of the property involved and whether there was full knowledge and independent advice about each spouse’s rights. When an oral prenuptial agreement does not purport to waive a spouse’s right to an equitable distribution of marital property, Matson does not apply. Matson, 107 Wn.2d at 482 . Here, the terms of the parties’ agreement were clear and straightforward. There was no provision of that agreement, however, that directed the trial court to dispose of the parties’ property in any particular manner upon dissolution or purported to waive a spouse’s interest to an equitable *365 distribution of property. Accordingly, it is an agreement that falls outside of Matson. Nevertheless, even if we were to evaluate the agreement for fairness, as the trial court did, we agree with the trial court that the prenuptial agreement satisfies the Matson test. Under the agreement, each party was able to and did accumulate substantial separate property. Cf. Matson, 107 Wn.2d at 486 (agreement voided because it prevented wife from accumulating her own separate property or making any claim against her husband’s separate property, to which husband devoted substantial time and energy during marriage); In re Marriage of Foran, 67 Wn App. 242, 248, 834 P.2d 1081 (1992). There is nothing unfair about two well-educated working professionals agreeing to preserve the fruits of their labor for their individual benefit. Indeed, as the one requesting the agreement, George apparently assumed that he had greater financial security, since he already owned some real estate and had a good job. Although in hindsight George may have been mistaken, this does not change the court’s analysis. Both parties were aware of each other’s education, assets, and income potential and had ample time to consider the agreement during their 5-year engagement and 14-year marriage. We conclude that the agreement was both procedurally and substantively fair to both parties. George’s next contention is that the trial court erred by “failing to make a fair and equitable property division,” as required by RCW 26.09.080. The record shows, however, that all of the parties’ separate and community property was before the court, which did exercise its discretion to make an equitable division of property. 1 Therefore, we do *366 not address George’s argument that a trial court is always required to comply with RCW 26.09.080, even if a valid prenuptial agreement provides a different disposition. As we have already concluded, the agreement at issue here did not bind the parties to any division of property upon dissolution. The trial court properly considered the parties’ prenuptial agreement and the RCW 26.09.080 factors in making its distribution. Moreover, “[t]he trial court has broad discretion in awarding property in a dissolution action, and will be reversed only upon a showing of manifest abuse of discretion.” In re Marriage of Fiorito, 112 Wn. App. 657, 667-68 , 50 P.3d 298 (2002). Just and equitable distribution does not mean that the court must make an equal distribution. Friedlander, 80 Wn.2d at 305 . In a well-reasoned oral opinion, the trial court fully set forth tenable grounds for dividing the parties’ property in accordance with the parties’ prenuptial agreement. The court’s disposition relied in part on the fact that each party accumulated substantial separate property during the marriage and both parties are capable of working full-time and continuing to accumulate and manage their assets. Based upon the parties’ agreement and expectations under that agreement, it cannot be said that the trial court’s property distribution was an abuse of discretion. Lastly, we address George’s contention that the trial court erred when it imputed income of $48,000 to him even though he now earns less money in his two part-time jobs for UPS and as a longshoreman. George claims that his part-time jobs constitute full-time employment and that the trial court could not have imputed income if he were *367 working full-time. He also claims that he cannot earn $48,000 per year without changing jobs or working in excess of 40 hours; thus, the amount of income imputed was an abuse of the court’s discretion. Neither claim has merit. An award of child support is reviewed for an abuse of discretion. In re Marriage of Curran, 26 Wn. App. 108, 110 , 611 P.2d 1350 (1980). Under RCW 26.19.071(6), the trial court must impute income to a parent who is voluntarily underemployed. The court first determines whether or not a parent is voluntarily underemployed based upon the parent’s work history, education, health, age, and other relevant factors. In re Marriage of Peterson, 80 Wn. App. 148, 153 , 906 P.2d 1009 (1995). “If a parent is underemployed but also ‘gainfully employed on a full-time basis,’ the court must make a further determination as to whether the parent is ‘purposely underemployed to reduce the parent’s child support obligation.’ ” Peterson, 80 Wn. App. at 153 (quoting RCW 26.19.071(6)). The court may not impute income to a parent who is gainfully employed full-time unless the court finds that the parent is voluntarily underemployed and is purposefully underemployed to reduce the parent’s child support obligation. RCW 26.19-.071(6). The trial court found that George was voluntarily underemployed and imputed income at a level of $48,000 per year for the purposes of child support. The facts pertinent to the court’s determination were that George is a healthy, 47-year-old college graduate with a history of executive-type sales and marketing jobs. In late 1999, George lost a job where he earned $55,000 per year. George testified that he started working 20 hours per week at $10 per hour at United Parcel Service in January 2000 because it provided good benefits for part-time work. This job gave him the flexible schedule required for him to work toward the requirements for a new career as a longshoreman. George does not argue that he is unemployable, and all of the evidence indicates that his underemployment has been brought about by his own free choice. See In re Marriage of *368 Brockopp, 78 Wn. App. 441 , 446 n.5, 898 P.2d 849 (1995). While there was no suggestion that George is trying to lower his income to avoid child support, the trial court’s determinations that George is not employed full-time and is voluntarily underemployed are supported by the record. We also reject George’s argument that it was improper to impute his income at a level higher than he could earn from 40 hours of longshore work. In Peterson, we held that it was an abuse of discretion to impute income based upon national averages after the trial court found that the full-time work with below average salary was consistent with the parent’s work history. Peterson, 80 Wn. App. at 154 . Basing George’s imputed income on the salary levels he maintained during the 1990s was reasonable and appropriate under RCW 26.19.071(6). George has requested an award of his attorney fees on appeal pursuant to RCW 26.09.140. Based upon the record, it appears that both parties have sufficient financial resources to pay their own attorney fees. Accordingly, we decline his request. We affirm. Cox, A.C.J., and Grosse, J., concur. Reconsideration denied March 5, 2003. Review denied at 150 Wn.2d 1006 (2003). The trial court awarded $300,000 of DewBerry’s separate property to George to balance the property distribution, stating: Then the real question for me is: Does equity require or suggest that more should be distributed because of the disparity of their incomes at this time, and because of the length of the marriage, which is, I guess, of moderate length? I do think that, given the good fortunes and the bad fortunes that have evolved on these parties, that Ms. DewBerry herself recognized that equity may require more. She has offered $300,000. I would say that it is difficult to judge these things, but it would seem to me that her ability to earn the kind of monies that she has made in the last several years has been assisted by Mr. George’s *366 parenting. I think it is clear that it is harder as a single parent to both work to your full capacity and also meet your parenting responsibilities, and she recognizes this by her testimony that she may have to cut back her hours to spend more time with the children. I do feel that further equitable distribution is appropriate and I will adopt the figure of $300,000 that she proposed. An additional $300,000 cash is an equity distribution from her separate property. Case-law data current through December 31, 2025. Source: CourtListener bulk data . A public interest project of Aaron Hall, Attorney at Law © 2026 About Federal Minnesota California New York Texas Terms Data from CourtListener / Free Law Project ↑ \ No newline at end of file diff --git a/.research/fleege.html b/.research/fleege.html new file mode 100644 index 0000000..ef853cd --- /dev/null +++ b/.research/fleege.html @@ -0,0 +1,21 @@ +In Re the Marriage of Fleege, 588 P.2d 1136 (Wash. 1979) | HallApproved.com
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Washington Supreme Court, 1979 +

In Re the Marriage of Fleege

In Re the Marriage of Fleege
Washington Supreme Court · Decided January 4, 1979 · Rosellini, Stafford
588 P.2d 1136; 91 Wash. 2d 324; 1979 Wash. LEXIS 1157 +(Pacific Reporter, Second Series)

In Re the Marriage of Fleege

Opinion of the Court

*325Rosellini, J.

On this appeal from a decree of marriage dissolution, entered April 13, 1976, error is assigned to the Superior Court's determination that the goodwill of the husband's dental practice was not an asset subject to division as a part of the community property.

The parties, who were both 58 years of age at the time of trial, had been married for approximately 32 years. They have five children, and the appellant, trained as a dietician, has not been gainfully employed during the marriage.

The respondent is a dentist, from whose practice the net profits in 1975 were $106,452.61. At the trial, the appellant presented the testimony of two certified public accountants, both of whom served clients in the medical and dental professions, who testified that the value of the respondent's practice included a goodwill factor, which had a present value. One of these set the value of the practice (evidently including accounts receivable and tangible property) at approximately $200,000. The other gave his opinion that the value of the goodwill would be equal to the gross receipts over a 2- to 3-month period. One of the experts stated that the respondent's net annual profits exceeded those of the average practitioner by approximately $50,000.

Challenging this expert testimony, the respondent produced a dentist who declared that he had never known of a dentist selling his practice and including a factor of goodwill amounting to more than a few dollars.

Despite the overwhelming evidence of the existence of an element of goodwill in the respondent's practice, the court refused to include it as an asset subject to distribution. In this the court erred.

Goodwill is property of an intangible nature and is commonly defined as the expectation of continued public patronage. In re Marriage of Lukens, 16 Wn. App. 481, 558 P.2d 279 (1976); In re Marriage of Foster, 42 Cal. App. 3d 577, 117 Cal. Rptr. 49 (1974). Among the elements which engender goodwill are continuity of name, location, reputation for honest and fair dealing, and individual talent and *326ability. In re Estate of Giant, 57 Wn.2d 309, 356 P.2d 707 (1960).

At the time this case was decided in the Superior Court, no appellate court in this state had ruled upon the question whether goodwill can attach to a professional practice, as well as to a commercial business. Subsequently, the well-considered opinion in In re Marriage of Lukens, supra, was published. In that opinion, conflicting arguments which are also presented in this case were analyzed, the authorities examined, and the conclusion reached that goodwill is indeed a factor which has value to a professional person and should be included among the assets distributed upon a marriage dissolution. We approve both the reasoning and the result reached in that case.

As the Court of Appeals pointed out, while the goodwill of a professional practice may not be readily marketable and the determination of its exact value may be difficult, that element may nevertheless be found to exist in a given professional practice. The determination of its value can be reached with the aid of expert testimony and by consideration of such factors as the practitioner's age, health, past earning power, reputation in the community for judgment, skill, and knowledge, and his comparative professional success.

A dentist who has practiced many years and established a good reputation can expect his patients to return to him and to speak of him in a manner that enhances that reputation and encourages others to seek his services. Also, he can expect a large number, if not most, of these patients to accept as their dentist a person to whom he sells his practice. These prospects are a part of goodwill, and they have a real pecuniary value.

The respondent argues that the goodwill of a dental practice is not "true" goodwill, because it cannot be successfully transferred to a purchaser^vithout certain services being performed by the practitioner. These services consist of introductions to the seller's patients and encouragement of patients to accept the buyer as their dentist. He insists *327that the amount purportedly paid for "goodwill" is in fact paid for these services, and represents "future earnings" which are not subject to division as community property.

The testimony of the accountants, both of whom had large numbers of doctors and dentists among their clients, shows, however, that goodwill exists in a going practice, whether or not a sale is in the offing. Documents brought to this court by the respondent indicate that prospective purchasers are interested in the quality of the practice — not merely a dentist's willingness to introduce them to patients. They show that subsequent to the entry of the decree below, the respondent attempted to sell his practice through ads in professional periodicals. Numerous similar advertisements appeared in these journals. Each describes the thing for sale as a dental "practice." Only one or two contain an offer to stay and introduce the purchaser to the seller's patients. But assuming such services are necessary, they are not the thing sold as "goodwill," but simply the means of transferring it.

In any event, the important consideration in this marriage dissolution case is not whether the goodwill of the practice could be sold without the personal services of the respondent to effectuate its transfer, but whether it has a value to him. This fact is well brought out in In re Marriage of Foster, supra, where it was conceded that the goodwill of the appellant's medical practice was community property subject to distribution, the only question being whether the proper method of evaluation had been used in the lower court. There had been no testimony as to what a willing buyer would pay or a willing seller would accept for the goodwill of the practice. However, a certified public accountant, declared by the court to be a proper expert in the matter, had given his opinion of the value of the goodwill in the doctor's medical practice. In sustaining a judgment adopting that value, the California appellate court said:

The value of community goodwill is not necessarily the specified amount of money that a willing buyer would *328pay for such goodwill. In view of exigencies that are ordinarily attendant [upon] a marriage dissolution the amount obtainable in the marketplace might well be less than the true value of the goodwill. Community goodwill is a portion of the community value of the professional practice as a going concern on the date of the dissolution of the marriage. As observed in Golden [v. Golden, 270 Cal. App. 2d 401, 75 Cal. Rptr. 735 (1969)], ". . . in a matrimonial matter, the practice of the sole practitioner husband will continue, with the same intangible value as it had during the marriage. Under the principles of community property law, the wife, by virtue of her position of wife, made to that value the same contribution as does a wife to any of the husband's earnings and accumulations during marriage. She is as much entitled to be recompensed for that contribution as if it were represented by the increased value of stock in a family business." (270 Cal.App.2d 401, 405.)

(Footnote omitted.) In re Marriage of Foster, supra at 584.

The respondent's ads in professional journals proclaimed that his practice grossed over $225,000 per year, a fact which would have been of no interest to a prospective buyer if all that was being purchased was the respondent's equipment and accounts receivable (the only aspects of the practice to which the trial court attributed value). This and other advertisements appearing in the journals constitute convincing evidence that there is a market for the sale of dental practices, and that such practices include more than equipment and accounts receivable.

The respondent sold his practice to his son within a year after the decree was entered, thus relieving himself of the obligation to make support payments under the decree. The purchase price was $80,000, which was approximately $32,000 more than the value of the equipment and accounts receivable which was found by the trial court. Furthermore, the accounts receivable had been reduced by $5,000 at the time of the sale. While the respondent avers' and the contract of sale recited that none of this $37,000 was attributable to goodwill, he offers no other explanation for it. Not only does the selling price reflect an amount paid for the *329intangible value of goodwill, but it can be assumed that a father, selling to his son, would be less inclined to demand the full value than he would be if he were selling to a stranger.

While there have been a number of courts which have refused to assign a value to the goodwill of a professional practice in a divorce proceeding, the modern tendency is to acknowledge the economic facts and take such goodwill into account. See Annot., Accountability for Good Will of Professional Practice in Actions Arising from Divorce or Separation, 52 A.L.R.3d 1344 (1973). 38 Am. Jur. 2d Good Will § 8 (1968); 38 C.J.S. Good Will § 3 (1943) and § 3 n.41 (Supp. 1978). California, a jurisdiction whose liberal approach with respect to community property we adopted in Wilder v. Wilder, 85 Wn.2d 364, 534 P.2d 1355 (1975),1 is firmly committed to this view. That the goodwill of a profession is a salable asset has long been recognized in Oregon. See Thompson Optical Inst. v. Thompson, 237 P. 965 (Ore. 1925), wherein many cases involving the sale of medical practices are cited. The New Mexico Supreme Court has recently said that the better rule is that goodwill exists in a professional practice and is salable. Durio v. Johnson, 68 N.M. 82, 358 P.2d 703 (1961).

Another persuasive case is Rees v. United States, 187 F. Supp. 924 (D. Ore. 1960), aff'd, 295 F.2d 817 (9th Cir. 1961). That was an action for the refund of certain income taxes. The taxpayer, an orthodontist, had entered into a partnership with other dentists, who had paid him $35,000 for the interest which they thereby acquired in the goodwill of his previous practice. It was argued that since the dentist's professional skill and reputation were taken into account in arriving at the purchase price, the entire amount could not be classed as a capital asset. This proposition was rejected, the court remarking that such factors were of the *330kind that any practical businessman would have considered in determining what he would pay for the goodwill of a business or profession.

The value of goodwill to the professional spouse, enabling him to continue to enjoy the patronage engendered by that goodwill, constitutes a community asset and should be considered by the court in distributing the community property. That value is real, and the mere fact that it cannot be precisely determined should not deter the court from assigning it a reasonable value within the evidence. Just as in other areas of the law where precise proof cannot be made, such difficulty does not constitute an insurmountable obstacle. Where, as was the case here at the time of trial, a professional man is approaching retirement age, the salable value of his practice should also be approximately determinable and is a factor to be taken into account.

The cause is remanded to the Superior Court with directions to determine the value of the goodwill of the respondent's practice, as it existed at the date of dissolution, taking into account the testimony of the experts and the other factors which we have mentioned. The court may call for additional evidence if that is deemed desirable. The property distribution should be revised accordingly.

Wright, C.J., and Hamilton, Utter, and Hicks, JJ., concur.

The held there that a retirement pension, although it had not vested at the time of a marriage dissolution, should be taken into consideration in making the community property distribution.

Dissenting Opinion

Stafford, J.

I dissent. In the instant case the majority has oversimplified important facts on the subject of goodwill. For example, it has down-played the fact that the goodwill in question is not similar to commercial goodwill in general. It is connected with a dental practice which is covered by specific laws governing the use of one's name. Also, the role of the sole dental practitioner is all but ignored.

Further, the majority has chosen to place its reliance upon the testimony of two experts obviously rejected by the trial court and has rejected the testimony of a third expert *331which the trial court clearly accepted on the subject of goodwill. The majority preferred and used the expert testimony with which it chose to agree rather than that which was accepted by the trial court. This is not a proper appellate function when there is conflicting testimony, the trial court has seen and heard the experts and clearly has given greater weight to the one it felt had the most credibility, and where there is substantial evidence to support the trial court's finding. Under these circumstances the constitution does not authorize an appellate court to substitute its judgment for that of the trial court. Thorndike v. Hesperian Orchards, Inc., 54 Wn.2d 570, 343 P.2d 183 (1959). In this case the trial court chose to believe an expert who was a dentist with over 40 years of practice in this state, who had himself sold his sole dental practice, who had assisted attorneys and widows of dentists to liquidate dental practices and who had assisted young dentists to acquire existing practices.

Usually it is not necessary to restate the facts, but in this case I must do it so the issue of goodwill actually involved herein may be viewed in its correct setting.

The Fleeges were married in 1943. During the marriage Dr. Fleege established a substantial dental practice. In 1975 he netted approximately $106,000 as a sole practitioner specializing in children's dentistry.

In 1976, Dr. Fleege filed for a dissolution of the marriage. At trial the only dispute was concerned with whether the goodwill of Dr. Fleege's dental practice was an asset subject to division. Three experts testified on the issue. Each based his opinion upon experience with sales of dental practices in which the selling dentist retired following a short-term association with the purchasing dentist. One expert, a dentist, testified that any goodwill associated with such sales had only minimal value and is paid to the retiring dentist to maintain that dentist's goodwill. The other two experts, certified public accountants, placed widely disparate values upon the goodwill of Dr. Fleege's practice. All experts agreed, however, that if a dentist should fail to dispose of *332his practice prior, to death any goodwill simply "evaporated" and would have no value as an asset.

The trial court valued the fixed assets of the practice at $47,373 and awarded them to Dr. Fleege. It assigned no value to goodwill and deemed it an asset incapable of division upon dissolution. After the decree of dissolution was entered Dr. Fleege sold his practice to his son and received nothing for goodwill.

Mrs. Fleege appealed the property division claiming that goodwill is a valuable asset which should have been considered in the division of property. It should be noted that after the notice of appeal was filed herein, Division Two of the Court of Appeals held that professional goodwill is an asset to be considered in a division of property. In re Marriage of Lukens, 16 Wn. App. 481, 558 P.2d 279 (1976). Division One of the Court of Appeals certified the instant appeal to this court.

The issue before this court is whether the goodwill of a sole professional practitioner of dentistry is a valuable asset subject to division in a dissolution of marriage. Initially, however, it is necessary to consider the general nature of goodwill.

Goodwill is most frequently associated with ongoing commercial ventures. In re Estate of Giant, 57 Wn.2d 309, 356 P.2d 707 (1960); J.L. Cooper & Co. v. Anchor Secs. Co., 9 Wn.2d 45, 113 P.2d 845 (1941); Stanton v. Zercher, 101 Wash. 383, 172 P. 559 (1918). In the commercial setting, goodwill includes the name, location, reputation for honesty and fair dealing, individual talents and abilities of the members of the organization. In re Estate of Giant, supra at 312; J.L. Cooper & Co. v. Anchor Secs. Co., supra at 54; Stanton v. Zercher, supra at 391-92. Goodwill comprises those advantages which may inure to a purchaser from holding himself out to the public as the successor in an enterprise which had been conducted in the past with the name and repute of his predecessor. Stanton v. Zercher, supra at 391. Because of its very nature the goodwill of an ongoing commercial venture inheres in the business and is *333inseparable from the whole. In re. Estate of Giant, supra at 312; Stanton v. Zercher, supra at 392; In re Marriage of Lukens, supra at 483-84.

Goodwill may also be generated in a professional venture such as the practice of dentistry, law, or medicine. But, such goodwill is personal in nature and is not a readily marketable commodity. See Lockhart v. Lockhart, 145 Wash. 210, 259 P. 385 (1927); In re Marriage of Lopez, 38 Cal. App. 3d 93, 113 Cal. Rptr. 58 (1974); Golden v. Golden, 270 Cal. App. 2d 401, 75 Cal. Rptr. 735 (1969). Factors contributing to a professional practitioner's goodwill include his name, age, health, past earning power, reputation for skill, judgment, and knowledge as well as his comparative success. In re Marriage of Lukens, supra at 484; In re Marriage of Lopez, supra at 68. The individual labor and individual attention of the professional practitioner are critical to establishing and maintaining goodwill. Lockhart v. Lockhart, supra at 213; Nail v. Nail, 486 S.W.2d 761, 763 (Tex. 1972).

Goodwill, whether generated by a commercial business or by a professional venture, is clearly "property" in a legal sense. See J.L. Cooper & Co. v. Anchor Secs. Co., supra at 53. However, to be true goodwill in the sense of a commodity with a salable value, it must have an existence separate from the continued presence of those who generated it. Goodwill of this nature may be sold precisely as other personal property may be sold. See J.L. Cooper & Co. v. Anchor Secs. Co., supra at 53. It follows that if goodwill of a professional practice exists, it will be an asset subject to division on dissolution of marriage if an appropriate value may be assigned to it as a salable commodity.

The next question is whether any goodwill exists, in connection with Dr. Fleege’s sole practice of dentistry, which may be valued in this dissolution proceeding.

Each expert testified that the "goodwill" associated with Dr. Fleege's sole practice of dentistry would have a value only if he had associated with a dental successor for a period of time and then retired. Thus, according to the only *334testimony on the subject, both the existence and value of that kind of "goodwill" are dependent upon a short-term association followed by Dr. Fleege's retirement. The trial court properly rejected this evidence and refused to distribute this so-called "goodwill" of Dr. Fleege's sole dental practice.

Clearly, the value assigned by the experts to Dr. Fleege's so-called "goodwill" represents a value assigned to a service for which a successor would be willing to pay Dr. Fleege for a temporary association prior to retirement. This concept and its value is not goodwill as the term is commonly used. Rather, it represents compensation to Dr. Fleege in exchange for a short-term association (i.e., his continued presence) followed by retirement. True goodwill must not depend upon the continued presence of the one who originally created it. It derives from the ability of a successor to enjoy the predecessor's name and reputation.

Further, considering the type of "goodwill" and allied valuation testified to by the experts herein it is important to note that in the profession of dentistry a successor could not lawfully enjoy Dr. Fleege's name and reputation without his continued active professional association. RCW 18.32.360 provides:

It shall be unlawful for any person to practice dentistry under any name, except his own, which shall be that used in his license issued by the director: Provided, That this shall not apply to any person who was practicing dentistry in this state on March 20, 1935, under an association or trade name.
It shall be unlawful for any person to conduct a dental office in his name, or to advertise his name in connection with any dental offices, unless he is personally present therein operating as a dentist, or personally overseeing the operations performed in any office, during most of the time that that office is being operated: Provided, That this section shall not prohibit any person from continuing to conduct any offices legally conducted in this state on March 20, 1935.
Any violation of the provisions of this section shall constitute improper, unprofessional and dishonorable *335conduct; it shall also constitute grounds for injunction proceedings as provided by this chapter, and in addition shall constitute a gross misdemeanor.

Consequently, neither the existence nor the value of "goodwill" discussed by the experts represents goodwill in its true sense. The trial court properly refused to consider such evidence as establishing either the existence of or the value of the goodwill of Dr. Fleege's sole dental practice.

I am also unable to find any evidence demonstrating the existence or value of the kind of "goodwill" here in question. The deficiency is understandable, however. Given the accepted understanding of goodwill, the nature of the dental profession, and RCW 18.32.360, the existence and value of a sole dental practitioner's goodwill, at the time of marriage dissolution, would be the same as its value if he should simply abandon it without more. Lockhart v. Lockhart, supra at 213. Total abandonment of a sole dental practice, while unusual, is analogous to the situation in which a dentist dies prior to selling the practice. In such an event, the three experts agreed any goodwill would simply "evaporate." It would no longer exist and would have no value.

If Dr. Fleege were to die or abandon his practice, any person thereafter using his name would be guilty of a gross misdemeanor. Since the very existence of professional goodwill derives from a successor's ability to enjoy the reputation associated with his predecessor and because another dentist could not enjoy Dr. Fleege's reputation without his continued presence, no true goodwill exists in connection with Dr. Fleege's sole practice to be valued in the marriage dissolution setting. Consequently, the trial court properly determined that the professional "goodwill" of Dr. Fleege's sole dental practice was not an asset capable of division in a marriage dissolution proceeding.

In resolving the issue at hand this court is not concerned with possible goodwill as an asset incident to sale of other types of professional practices, or goodwill that may exist in the setting of a professional partnership. We are concerned *336solely with a marital dissolution and the existence and valuation of goodwill generated by a dentist who is a sole practitioner.

The trial court should be affirmed.

Brachtenbach, Horowitz, and Dolliver, JJ., concur with Stafford, J.

Case-law data current through December 31, 2025. Source: CourtListener bulk data.

↑ + \ No newline at end of file diff --git a/.research/fleege.txt b/.research/fleege.txt new file mode 100644 index 0000000..b777cf0 --- /dev/null +++ b/.research/fleege.txt @@ -0,0 +1 @@ +In Re the Marriage of Fleege, 588 P.2d 1136 (Wash. 1979) | HallApproved.com Hall Approved Free Access to American Case Law Statutes Free Legal Archive / Washington / Cases / Washington Supreme Court / 1979 / Washington Supreme Court, 1979 Copy citation Free Legal Archive / Washington / Cases / Washington Supreme Court / 1979 / In Re the Marriage of Fleege In Re the Marriage of Fleege Washington Supreme Court · Decided January 4, 1979 · Rosellini, Stafford 588 P.2d 1136; 91 Wash. 2d 324; 1979 Wash. LEXIS 1157 (Pacific Reporter, Second Series) In Re the Marriage of Fleege Opinions Opinion of the Court Dissenting Opinion Opinion of the Court *325 Rosellini, J. On this appeal from a decree of marriage dissolution, entered April 13, 1976, error is assigned to the Superior Court's determination that the goodwill of the husband's dental practice was not an asset subject to division as a part of the community property. The parties, who were both 58 years of age at the time of trial, had been married for approximately 32 years. They have five children, and the appellant, trained as a dietician, has not been gainfully employed during the marriage. The respondent is a dentist, from whose practice the net profits in 1975 were $106,452.61. At the trial, the appellant presented the testimony of two certified public accountants, both of whom served clients in the medical and dental professions, who testified that the value of the respondent's practice included a goodwill factor, which had a present value. One of these set the value of the practice (evidently including accounts receivable and tangible property) at approximately $200,000. The other gave his opinion that the value of the goodwill would be equal to the gross receipts over a 2- to 3-month period. One of the experts stated that the respondent's net annual profits exceeded those of the average practitioner by approximately $50,000. Challenging this expert testimony, the respondent produced a dentist who declared that he had never known of a dentist selling his practice and including a factor of goodwill amounting to more than a few dollars. Despite the overwhelming evidence of the existence of an element of goodwill in the respondent's practice, the court refused to include it as an asset subject to distribution. In this the court erred. Goodwill is property of an intangible nature and is commonly defined as the expectation of continued public patronage. In re Marriage of Lukens, 16 Wn. App. 481 , 558 P.2d 279 (1976); In re Marriage of Foster, 42 Cal. App. 3d 577 , 117 Cal. Rptr. 49 (1974). Among the elements which engender goodwill are continuity of name, location, reputation for honest and fair dealing, and individual talent and *326 ability. In re Estate of Giant, 57 Wn.2d 309 , 356 P.2d 707 (1960). At the time this case was decided in the Superior Court, no appellate court in this state had ruled upon the question whether goodwill can attach to a professional practice, as well as to a commercial business. Subsequently, the well-considered opinion in In re Marriage of Lukens, supra, was published. In that opinion, conflicting arguments which are also presented in this case were analyzed, the authorities examined, and the conclusion reached that goodwill is indeed a factor which has value to a professional person and should be included among the assets distributed upon a marriage dissolution. We approve both the reasoning and the result reached in that case. As the Court of Appeals pointed out, while the goodwill of a professional practice may not be readily marketable and the determination of its exact value may be difficult, that element may nevertheless be found to exist in a given professional practice. The determination of its value can be reached with the aid of expert testimony and by consideration of such factors as the practitioner's age, health, past earning power, reputation in the community for judgment, skill, and knowledge, and his comparative professional success. A dentist who has practiced many years and established a good reputation can expect his patients to return to him and to speak of him in a manner that enhances that reputation and encourages others to seek his services. Also, he can expect a large number, if not most, of these patients to accept as their dentist a person to whom he sells his practice. These prospects are a part of goodwill, and they have a real pecuniary value. The respondent argues that the goodwill of a dental practice is not "true" goodwill, because it cannot be successfully transferred to a purchaser^vithout certain services being performed by the practitioner. These services consist of introductions to the seller's patients and encouragement of patients to accept the buyer as their dentist. He insists *327 that the amount purportedly paid for "goodwill" is in fact paid for these services, and represents "future earnings" which are not subject to division as community property. The testimony of the accountants, both of whom had large numbers of doctors and dentists among their clients, shows, however, that goodwill exists in a going practice, whether or not a sale is in the offing. Documents brought to this court by the respondent indicate that prospective purchasers are interested in the quality of the practice — not merely a dentist's willingness to introduce them to patients. They show that subsequent to the entry of the decree below, the respondent attempted to sell his practice through ads in professional periodicals. Numerous similar advertisements appeared in these journals. Each describes the thing for sale as a dental "practice." Only one or two contain an offer to stay and introduce the purchaser to the seller's patients. But assuming such services are necessary, they are not the thing sold as "goodwill," but simply the means of transferring it. In any event, the important consideration in this marriage dissolution case is not whether the goodwill of the practice could be sold without the personal services of the respondent to effectuate its transfer, but whether it has a value to him. This fact is well brought out in In re Marriage of Foster, supra, where it was conceded that the goodwill of the appellant's medical practice was community property subject to distribution, the only question being whether the proper method of evaluation had been used in the lower court. There had been no testimony as to what a willing buyer would pay or a willing seller would accept for the goodwill of the practice. However, a certified public accountant, declared by the court to be a proper expert in the matter, had given his opinion of the value of the goodwill in the doctor's medical practice. In sustaining a judgment adopting that value, the California appellate court said: The value of community goodwill is not necessarily the specified amount of money that a willing buyer would *328 pay for such goodwill. In view of exigencies that are ordinarily attendant [upon] a marriage dissolution the amount obtainable in the marketplace might well be less than the true value of the goodwill. Community goodwill is a portion of the community value of the professional practice as a going concern on the date of the dissolution of the marriage. As observed in Golden [v. Golden, 270 Cal. App. 2d 401 , 75 Cal. Rptr. 735 (1969)], ". . . in a matrimonial matter, the practice of the sole practitioner husband will continue, with the same intangible value as it had during the marriage. Under the principles of community property law, the wife, by virtue of her position of wife, made to that value the same contribution as does a wife to any of the husband's earnings and accumulations during marriage. She is as much entitled to be recompensed for that contribution as if it were represented by the increased value of stock in a family business." ( 270 Cal.App.2d 401, 405 .) (Footnote omitted.) In re Marriage of Foster, supra at 584. The respondent's ads in professional journals proclaimed that his practice grossed over $225,000 per year, a fact which would have been of no interest to a prospective buyer if all that was being purchased was the respondent's equipment and accounts receivable (the only aspects of the practice to which the trial court attributed value). This and other advertisements appearing in the journals constitute convincing evidence that there is a market for the sale of dental practices, and that such practices include more than equipment and accounts receivable. The respondent sold his practice to his son within a year after the decree was entered, thus relieving himself of the obligation to make support payments under the decree. The purchase price was $80,000, which was approximately $32,000 more than the value of the equipment and accounts receivable which was found by the trial court. Furthermore, the accounts receivable had been reduced by $5,000 at the time of the sale. While the respondent avers' and the contract of sale recited that none of this $37,000 was attributable to goodwill, he offers no other explanation for it. Not only does the selling price reflect an amount paid for the *329 intangible value of goodwill, but it can be assumed that a father, selling to his son, would be less inclined to demand the full value than he would be if he were selling to a stranger. While there have been a number of courts which have refused to assign a value to the goodwill of a professional practice in a divorce proceeding, the modern tendency is to acknowledge the economic facts and take such goodwill into account. See Annot., Accountability for Good Will of Professional Practice in Actions Arising from Divorce or Separation, 52 A.L.R.3d 1344 (1973). 38 Am. Jur. 2d Good Will § 8 (1968); 38 C.J.S. Good Will § 3 (1943) and § 3 n.41 (Supp. 1978). California, a jurisdiction whose liberal approach with respect to community property we adopted in Wilder v. Wilder, 85 Wn.2d 364 , 534 P.2d 1355 (1975), 1 is firmly committed to this view. That the goodwill of a profession is a salable asset has long been recognized in Oregon. See Thompson Optical Inst. v. Thompson, 237 P. 965 (Ore. 1925), wherein many cases involving the sale of medical practices are cited. The New Mexico Supreme Court has recently said that the better rule is that goodwill exists in a professional practice and is salable. Durio v. Johnson, 68 N.M. 82 , 358 P.2d 703 (1961). Another persuasive case is Rees v. United States, 187 F. Supp. 924 (D. Ore. 1960), aff'd, 295 F.2d 817 (9th Cir. 1961). That was an action for the refund of certain income taxes. The taxpayer, an orthodontist, had entered into a partnership with other dentists, who had paid him $35,000 for the interest which they thereby acquired in the goodwill of his previous practice. It was argued that since the dentist's professional skill and reputation were taken into account in arriving at the purchase price, the entire amount could not be classed as a capital asset. This proposition was rejected, the court remarking that such factors were of the *330 kind that any practical businessman would have considered in determining what he would pay for the goodwill of a business or profession. The value of goodwill to the professional spouse, enabling him to continue to enjoy the patronage engendered by that goodwill, constitutes a community asset and should be considered by the court in distributing the community property. That value is real, and the mere fact that it cannot be precisely determined should not deter the court from assigning it a reasonable value within the evidence. Just as in other areas of the law where precise proof cannot be made, such difficulty does not constitute an insurmountable obstacle. Where, as was the case here at the time of trial, a professional man is approaching retirement age, the salable value of his practice should also be approximately determinable and is a factor to be taken into account. The cause is remanded to the Superior Court with directions to determine the value of the goodwill of the respondent's practice, as it existed at the date of dissolution, taking into account the testimony of the experts and the other factors which we have mentioned. The court may call for additional evidence if that is deemed desirable. The property distribution should be revised accordingly. Wright, C.J., and Hamilton, Utter, and Hicks, JJ., concur. The held there that a retirement pension, although it had not vested at the time of a marriage dissolution, should be taken into consideration in making the community property distribution. Dissenting Opinion Stafford, J. I dissent. In the instant case the majority has oversimplified important facts on the subject of goodwill. For example, it has down-played the fact that the goodwill in question is not similar to commercial goodwill in general. It is connected with a dental practice which is covered by specific laws governing the use of one's name. Also, the role of the sole dental practitioner is all but ignored. Further, the majority has chosen to place its reliance upon the testimony of two experts obviously rejected by the trial court and has rejected the testimony of a third expert *331 which the trial court clearly accepted on the subject of goodwill. The majority preferred and used the expert testimony with which it chose to agree rather than that which was accepted by the trial court. This is not a proper appellate function when there is conflicting testimony, the trial court has seen and heard the experts and clearly has given greater weight to the one it felt had the most credibility, and where there is substantial evidence to support the trial court's finding. Under these circumstances the constitution does not authorize an appellate court to substitute its judgment for that of the trial court. Thorndike v. Hesperian Orchards, Inc., 54 Wn.2d 570 , 343 P.2d 183 (1959). In this case the trial court chose to believe an expert who was a dentist with over 40 years of practice in this state, who had himself sold his sole dental practice, who had assisted attorneys and widows of dentists to liquidate dental practices and who had assisted young dentists to acquire existing practices. Usually it is not necessary to restate the facts, but in this case I must do it so the issue of goodwill actually involved herein may be viewed in its correct setting. The Fleeges were married in 1943. During the marriage Dr. Fleege established a substantial dental practice. In 1975 he netted approximately $106,000 as a sole practitioner specializing in children's dentistry. In 1976, Dr. Fleege filed for a dissolution of the marriage. At trial the only dispute was concerned with whether the goodwill of Dr. Fleege's dental practice was an asset subject to division. Three experts testified on the issue. Each based his opinion upon experience with sales of dental practices in which the selling dentist retired following a short-term association with the purchasing dentist. One expert, a dentist, testified that any goodwill associated with such sales had only minimal value and is paid to the retiring dentist to maintain that dentist's goodwill. The other two experts, certified public accountants, placed widely disparate values upon the goodwill of Dr. Fleege's practice. All experts agreed, however, that if a dentist should fail to dispose of *332 his practice prior, to death any goodwill simply "evaporated" and would have no value as an asset. The trial court valued the fixed assets of the practice at $47,373 and awarded them to Dr. Fleege. It assigned no value to goodwill and deemed it an asset incapable of division upon dissolution. After the decree of dissolution was entered Dr. Fleege sold his practice to his son and received nothing for goodwill. Mrs. Fleege appealed the property division claiming that goodwill is a valuable asset which should have been considered in the division of property. It should be noted that after the notice of appeal was filed herein, Division Two of the Court of Appeals held that professional goodwill is an asset to be considered in a division of property. In re Marriage of Lukens, 16 Wn. App. 481 , 558 P.2d 279 (1976). Division One of the Court of Appeals certified the instant appeal to this court. The issue before this court is whether the goodwill of a sole professional practitioner of dentistry is a valuable asset subject to division in a dissolution of marriage. Initially, however, it is necessary to consider the general nature of goodwill. Goodwill is most frequently associated with ongoing commercial ventures. In re Estate of Giant, 57 Wn.2d 309 , 356 P.2d 707 (1960); J.L. Cooper & Co. v. Anchor Secs. Co., 9 Wn.2d 45 , 113 P.2d 845 (1941); Stanton v. Zercher, 101 Wash. 383 , 172 P. 559 (1918). In the commercial setting, goodwill includes the name, location, reputation for honesty and fair dealing, individual talents and abilities of the members of the organization. In re Estate of Giant, supra at 312; J.L. Cooper & Co. v. Anchor Secs. Co., supra at 54; Stanton v. Zercher, supra at 391-92. Goodwill comprises those advantages which may inure to a purchaser from holding himself out to the public as the successor in an enterprise which had been conducted in the past with the name and repute of his predecessor. Stanton v. Zercher, supra at 391. Because of its very nature the goodwill of an ongoing commercial venture inheres in the business and is *333 inseparable from the whole. In re. Estate of Giant, supra at 312; Stanton v. Zercher, supra at 392; In re Marriage of Lukens, supra at 483-84. Goodwill may also be generated in a professional venture such as the practice of dentistry, law, or medicine. But, such goodwill is personal in nature and is not a readily marketable commodity. See Lockhart v. Lockhart, 145 Wash. 210 , 259 P. 385 (1927); In re Marriage of Lopez, 38 Cal. App. 3d 93 , 113 Cal. Rptr. 58 (1974); Golden v. Golden, 270 Cal. App. 2d 401 , 75 Cal. Rptr. 735 (1969). Factors contributing to a professional practitioner's goodwill include his name, age, health, past earning power, reputation for skill, judgment, and knowledge as well as his comparative success. In re Marriage of Lukens, supra at 484; In re Marriage of Lopez, supra at 68. The individual labor and individual attention of the professional practitioner are critical to establishing and maintaining goodwill. Lockhart v. Lockhart, supra at 213; Nail v. Nail, 486 S.W.2d 761, 763 (Tex. 1972). Goodwill, whether generated by a commercial business or by a professional venture, is clearly "property" in a legal sense. See J.L. Cooper & Co. v. Anchor Secs. Co., supra at 53. However, to be true goodwill in the sense of a commodity with a salable value, it must have an existence separate from the continued presence of those who generated it. Goodwill of this nature may be sold precisely as other personal property may be sold. See J.L. Cooper & Co. v. Anchor Secs. Co., supra at 53. It follows that if goodwill of a professional practice exists, it will be an asset subject to division on dissolution of marriage if an appropriate value may be assigned to it as a salable commodity. The next question is whether any goodwill exists, in connection with Dr. Fleege’s sole practice of dentistry, which may be valued in this dissolution proceeding. Each expert testified that the "goodwill" associated with Dr. Fleege's sole practice of dentistry would have a value only if he had associated with a dental successor for a period of time and then retired. Thus, according to the only *334 testimony on the subject, both the existence and value of that kind of "goodwill" are dependent upon a short-term association followed by Dr. Fleege's retirement. The trial court properly rejected this evidence and refused to distribute this so-called "goodwill" of Dr. Fleege's sole dental practice. Clearly, the value assigned by the experts to Dr. Fleege's so-called "goodwill" represents a value assigned to a service for which a successor would be willing to pay Dr. Fleege for a temporary association prior to retirement. This concept and its value is not goodwill as the term is commonly used. Rather, it represents compensation to Dr. Fleege in exchange for a short-term association (i.e., his continued presence) followed by retirement. True goodwill must not depend upon the continued presence of the one who originally created it. It derives from the ability of a successor to enjoy the predecessor's name and reputation. Further, considering the type of "goodwill" and allied valuation testified to by the experts herein it is important to note that in the profession of dentistry a successor could not lawfully enjoy Dr. Fleege's name and reputation without his continued active professional association. RCW 18.32.360 provides: It shall be unlawful for any person to practice dentistry under any name, except his own, which shall be that used in his license issued by the director: Provided, That this shall not apply to any person who was practicing dentistry in this state on March 20, 1935, under an association or trade name. It shall be unlawful for any person to conduct a dental office in his name, or to advertise his name in connection with any dental offices, unless he is personally present therein operating as a dentist, or personally overseeing the operations performed in any office, during most of the time that that office is being operated: Provided, That this section shall not prohibit any person from continuing to conduct any offices legally conducted in this state on March 20, 1935. Any violation of the provisions of this section shall constitute improper, unprofessional and dishonorable *335 conduct; it shall also constitute grounds for injunction proceedings as provided by this chapter, and in addition shall constitute a gross misdemeanor. Consequently, neither the existence nor the value of "goodwill" discussed by the experts represents goodwill in its true sense. The trial court properly refused to consider such evidence as establishing either the existence of or the value of the goodwill of Dr. Fleege's sole dental practice. I am also unable to find any evidence demonstrating the existence or value of the kind of "goodwill" here in question. The deficiency is understandable, however. Given the accepted understanding of goodwill, the nature of the dental profession, and RCW 18.32.360, the existence and value of a sole dental practitioner's goodwill, at the time of marriage dissolution, would be the same as its value if he should simply abandon it without more. Lockhart v. Lockhart, supra at 213. Total abandonment of a sole dental practice, while unusual, is analogous to the situation in which a dentist dies prior to selling the practice. In such an event, the three experts agreed any goodwill would simply "evaporate." It would no longer exist and would have no value. If Dr. Fleege were to die or abandon his practice, any person thereafter using his name would be guilty of a gross misdemeanor. Since the very existence of professional goodwill derives from a successor's ability to enjoy the reputation associated with his predecessor and because another dentist could not enjoy Dr. Fleege's reputation without his continued presence, no true goodwill exists in connection with Dr. Fleege's sole practice to be valued in the marriage dissolution setting. Consequently, the trial court properly determined that the professional "goodwill" of Dr. Fleege's sole dental practice was not an asset capable of division in a marriage dissolution proceeding. In resolving the issue at hand this court is not concerned with possible goodwill as an asset incident to sale of other types of professional practices, or goodwill that may exist in the setting of a professional partnership. We are concerned *336 solely with a marital dissolution and the existence and valuation of goodwill generated by a dentist who is a sole practitioner. The trial court should be affirmed. Brachtenbach, Horowitz, and Dolliver, JJ., concur with Stafford, J. Case-law data current through December 31, 2025. Source: CourtListener bulk data . A public interest project of Aaron Hall, Attorney at Law © 2026 About Federal Minnesota California New York Texas Terms Data from CourtListener / Free Law Project ↑ \ No newline at end of file diff --git a/.research/friedlander.html b/.research/friedlander.html new file mode 100644 index 0000000..b761498 --- /dev/null +++ b/.research/friedlander.html @@ -0,0 +1,182 @@ +Friedlander v. Friedlander, 494 P.2d 208 (Wash. 1972) | HallApproved.com
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Washington Supreme Court, 1972 +

Friedlander v. Friedlander

Friedlander v. Friedlander
Washington Supreme Court · Decided February 24, 1972 · Stafford
494 P.2d 208; 80 Wash. 2d 293; 1972 Wash. LEXIS 586 +(Pacific Reporter, Second Series)

Friedlander v. Friedlander

Opinion

Stafford, J.

Mr. John M. Friedlander (hereafter called the plaintiff) instituted an action for divorce against his wife, Polly (hereafter called the defendant). Defendant also sought a divorce from plaintiff. Each was granted a +*295 +divorce. Defendant was awarded substantially all community property whereas plaintiff received his own separate property. Defendant appeals.

In 1955, defendant, a divorcee, began an affair with the plaintiff that lasted for approximately 5 years. Plaintiff’s then wife became acutely aware of the situation and, after a bitterly contested action in 1960, dissolved a marriage of 27 years standing. Much of plaintiff’s separate property, involved in this appeal, formed the subject of a similar appeal in +Friedlander v. Friedlander, +58 Wn.2d 288, 362 P.2d 352 (1961).

Immediately following the divorce from Elizabeth, plaintiff and defendant discussed marriage. However, having just experienced one unpleasant dispute over property, plaintiff suggested that he and defendant enter into a prenuptial agreement.

Essentially, the agreement provided that separate property owned by either party prior to the contemplated marriage would remain separate property, together with all rents, issues and profits therefrom. It specifically mentioned that plaintiff’s separate property consisted “principally of his holdings in the various Friedlander family enterprises and his contingent interest in the trust estate of Louis Friedlander, deceased.” Defendant agreed, in the event of a divorce, to “make no claim in any proceedings for any of the separate property of John M. Friedlander, or the rents, issues and profits thereof.” Although not specified in the prenuptial agreement, the “Friedlander family enterprises” in 1960 consisted of Friedlander and Sons, a corporation, which owned and operated a number of jewelry stores; LouBelle Realty Co., a corporation which owned land upon which the Logan Building was erected; P & J Wholesale Jewelers, a co-partnership; the Merton-Singerman Agency, a co-partnership; and the trust estate of Louis Friedlander, deceased.

The parties were married 2 days after signing the prenuptial agreement. At the time defendant had virtually no +*296 +separate property and she acquired none during the marriage.

The parties acquired a relatively small amount of community property. They lived on plaintiff’s salary which ranged from approximately $26,000 in 1960 to about $47,000 in 1969. Plaintiff derived other income from profits of the various “Friedlander family enterprises” and from the investment in securities which were his separate property. +No +children were born during the marriage.

Defendant furthered her education during the ensuing years and completed all but two quarters for her fine arts degree. Unfortunately, the same period produced marital discord. Finally, each sought a divorce from the other claiming “cruel and inhuman treatment.”

At the beginning of the marriage, the owners’ interest in the various “Friedlander family enterprises” was valued at about $1,041,183, approximately one-third of which belonged to plaintiff. When the marriage was dissolved in 1970, the owners’ equity had increased to approximately $1,297,243. Plaintiff’s share therein had been substantially increased by the death of his mother.

The trial court granted each party a divorce. Plaintiff was awarded the community’s interest in the profit sharing trust of Friedlander and Sons, Inc., and all of his separate property which the court listed as his interest in Friedlan-der and Sons, Inc.; LouBelle Realty; P & J Wholesale Jewelry; Merton-Singerman Agency; an interest in the Louis Friedlander trust; an inheritance from his mother; and, his interest in various life insurance policies that had been owned prior to the marriage. In short, plaintiff’s share was essentially that provided for in the prenuptial agreement.

Defendant was awarded most of the community property, which consisted of the family home and household furnishings; four vacant lots; the proceeds of a savings account and an automobile, all of which had a net value of about $32,000. She was also awarded alimony of $500 a month for 3 years, together with costs and attorneys’ fees.

*297 +Defendant appeals making 10 assignments of error which raise five basic issues.

I

The Husband’s Entitlement to Divorce for Mental Cruelty

Defendant asserts that she alone was entitled to a decree of divorce based upon cruel and inhuman treatment. The assignment of error is not well taken.

When two parties have sued for divorce on similar grounds, an appellant will not be heard to claim that the trial court erred by granting a divorce to the other spouse as well. +Akins v. Akins, +51 Wn.2d 887, 322 P.2d 872 (1958). In such a case, error, if any, is not prejudicial.

II

The Adequacy of Alimony

Defendant asserts that prior to marriage she worked to support herself and child and lived in modest circumstances. In contrast, she contends, the marriage introduced her to a higher standard of living to which she has now become accustomed. She argues that she will be unable to maintain that standard. Thus, it is said, the trial court abused its discretion by granting her alimony of only $500 a month for 3 years.

While this is an engaging argument, it is not a proper basis for awarding alimony. +Morgan v. Morgan, +59 Wn.2d 639, 369 P.2d 516 (1962). Alimony is not a matter of right. +Kelso v. Kelso, +75 Wn.2d 24, 27, 448 P.2d 499 (1968). It is based upon +two +factors: (1) the necessities of the wife +and +(2) the financial ability of the husband to pay. +Kelso v. Kelso, supra; Murray v. Murray, +26 Wn.2d 370, 378, 174 P.2d 296 (1946). The maintenance of a lifestyle to which one has become accustomed is not a test of +need. Morgan v. Morgan, supra.

Further, defendant’s child by a previous marriage is no +*298 +longer dependent upon her for support. Defendant is only 40 years of age. She assigns no error to the trial court’s findings of fact that she is in good health; that she is within two quarters of completing her fine arts degree at the University of Washington; and that she is capable of earning her own living. The record also reveals that she is engaged in the commercial operation of an art gallery which, according to her brief, is “a business for which her education and abilities give her qualifications . . .” The indication is that the prospect for the business is good, although it may take some time to establish the gallery’s name.

We cannot say that the trial court abused its discretion either in the amount or the duration of the alimony. Abuse of discretion is not shown -unless the discretion has been exercised upon a ground, or to an extent, clearly untenable or manifestly unreasonable. +Malfait v. Malfait, +54 Wn.2d 413, 341 P.2d 154 (1959); +High v. High, +41 Wn.2d 811, 252 P.2d 272 (1953); +Berol v. Berol, +37 Wn.2d 380, 223 P.2d 1055 (1950). +See also State ex rel. Beffa v. Superior Court, +3 Wn.2d 184, 100 P.2d 6 (1940). Defendant has failed to demonstrate the requisite +need +for additional funds.

Ill

The Prenuptial Agreement

Both parties, as well as the trial court, have characterized the questioned instrument as a “prenuptial agreement.” In citing +Hamlin v. Merlino, +44 Wn.2d 851, 272 P.2d 125 (1954), each party has also referred to it as an “antenuptial” agreement. However, these two designations are synonymous and the parties have so treated them. 2 A. Lindey, Separation Agreements' and Ante-Nuptial Contracts § 90, at 22-23 (rev. ed. 1967).

It is significant that the transaction involves a +prenuptial agreement +as distinguished from a +postnuptial or separation agreement +and that it has been so treated by the parties and the trial court as well. A prenuptial agreement is one entered into by prospective spouses +prior to marriage +*299 +but in contemplation and in consideration thereof. By it, the property rights of one or both of the prospective spouses are determined or are secured to one or both of them or to their children. On the other hand, postnuptial agreements or settlements are made after marriage +between couples still married. +They take the form of (a) separation agreements; (b) property settlements in contemplation of a separation or divorce; (c) property settlements where there is no intention of the parties to separate. 2 A. Lindey, § 90, at 22-23; 1 W. Nelson, Divorce and Annulment § 13.02, at 485 (2d ed. 1945).

It is also important that although defendant challenges the validity of the prenuptial agreement, based upon the conditions that surrounded its making, neither party contends that prenuptial contracts, as such, are contrary to public policy, if freely and intelligently made. +Hamlin v. Merlino, supra; +2 A. Lindey, § 90, at 30; +see also +1 W. Nelson, § 13.03; 41 Am. Jur. 2d +Husband and Wife +§ 283 (1968). Finally, neither party raises the question whether the prenuptial agreement was made in contemplation of or is promotive of divorce, and if so, whether it is void as against public policy for that reason. +1 +Thus, there is no need to resolve either of the immediately preceding questions in this case. We are here concerned with whether the prenuptial agreement, assuming its proper use in this type of transaction, is valid as between these parties under the rules governing prenuptial agreements.

First, defendant argues that there was no considera +*300 +tion for the agreement because plaintiff had previously proposed marriage. This position, however, finds no support in the authorities. Marriage is not only, adequate, but is consideration of the highest value. 2 A. Lindey, § 90, at 32-33; 41 Am. Jur. 2d +Husband and Wife +§ 285, at 235 ,(1968); +In re Estate of Onstot, +224 Iowa 520, 277 N.W. 563 (1938); +see also +1 W. Nelson, § 13.03. Further, the agreement contained mutual waivers by the parties. This also is adequate consideration for a prenuptial agreement. 2 A. Lindey, § 90, at 34; 41 Am. Jur. 2d +Husband and Wife +§ 285, at 235 (1968).

Next, defendant contends the trial court erred by finding: “. . . +Polly Friedlander has not sustained the burden of proving that the +[prenuptial] agreement was not executed in good faith . . .” (Italics ours.) The finding of fact was proposed by plaintiff’s attorney. However, during oral argument he conceded that it incorrectly shifted, to defendant, the burden of proving the prenuptial agreement was not executed in good faith.

Obviously, counsel's concession has placed the trial court in an awkward position. Nevertheless, it comports with the law relative to prenuptial agreements. Generally speaking, the burden of establishing full disclosure or fairness rests upon the party asserting the prenuptial agreement +(i.e., +the plaintiff husband herein). 2 A. Lindey, § 90, at 38 and 85; 41 Am. Jur. 2d +Husband and Wife +§ 313, at 254 (1968). As stated in 2 A. Lindey, § 90, at 84:

where the provision made for the wife is disproportionate to the property of the husband, a presumption arises that the contract was procured by deliberate concealment of the amount and value of the husband’s property; and the husband or those claiming under him against the wife have the burden of showing that she had full knowledge of the value of her interest in the husband’s property, or that the circumstances were such that she reasonably should have had such knowledge.[ +2 +]

*301 +The trial court erred by finding that defendant had the burden of proving the agreement was not executed in good faith.

A prenuptial agreement freely and intelligently made is generally regarded as conducive to marital tranquility and the avoidance of disputes about property in the future. 2 A. Lindey, § 90, at 30. For that reason, it is regarded with favor. But, the beneficial possibilities of such contracts must be preserved without the attendant dangers of abuse.

With this in mind the relationship of the parties to the contract becomes of primary importance. It is well recognized that even an engagement to marry creates a confidential relationship. +Hamlin v. Merlino, +44 Wn.2d 851, 865, 272 P.2d 125 (1954); +Juhasz v. Juhasz, +134 Ohio St. 257, 264, 16 N.E.2d 328, 117 A.L.R. 993 (1938). Parties to a prenuptial agreement do not deal with each other at arm’s length. Their relationship is one of mutual confidence and trust which calls for the exercise of good faith, candor and sincerity in all matters bearing upon the proposed agreement. +Bauer v. Bauer, +1 Ore. App. 504, 464 P.2d 710 (1970); 2 A. Lindey, § 90, at 38, 41.

The basic objective of this common sense rule is to prevent overreaching. 2 A. Lindey, § 90, at 240 (Supp. 1971). Where a prenuptial contract makes provision for a wife that is disproportionate to the means of the intended husband, it casts a burden upon the intended husband, and those claiming under him, to prove that she had full knowledge of all the facts and circumstances that materially affected the contract. +Juhasz v. Juhasz, supra; Warner v. Warner, +235 Ill. 448, 462, 85 N.E. 630 (1908).

Without question, the record in this case discloses that the prenuptial contract makes provision for the wife that is disproportionate to the means of the husband.

Plaintiff acknowledges that the establishment of good faith and full disclosure is his burden. However, he asserts that he has sustained it. He argues that he told defendant he had had many difficulties during the first divorce that he +*302 +did not want to encounter again. Plaintiff asserts that the agreement itself discloses the nature of the assets by referring to “property and assets, consisting primarily of his holdings in the various Friedlander family enterprises and his contingent interest in the trust estate of Louis Friedlan-der, deceased.” It is related that both Mr. Monheimer, an attorney for plaintiff and for the Friedlander family, and plaintiff’s brother, Paul (also an attorney), informed defendant generally of the nature and effect of a prenuptial agreement. Plaintiff indicated that defendant signed the agreement without objection, knowing that it involved property consisting of jewelry stores and the Logan Building realty.

It must be observed, however, that the statement of facts fails to reveal the content of any explanation made by Mr. Monheimer or Mr. Paul Friedlander. In fact, neither could have explained the substance of the actual agreement. At the time, it had not been drafted by Mr. Friedman, another of plaintiff’s attorneys. There is no evidence that defendant had anyone explain the contents of the written agreement to her. Finally, there is no evidence that anyone discussed with her the value of the property with which the prenuptial agreement was concerned.

This brings us to the nature of the good faith disclosure required by a prenuptial agreement. To render such an agreement valid there must be a fair and reasonable provision for the wife, or, in the absence thereof there must be a full, frank disclosure of the future husband’s property and his worth. +Juhasz v. Juhasz, supra; Warner v. Warner, supra; +2 A. Lindey, § 90, at 36-37. This is not to say that she must know the +exact +financial status of his resources. However, she must at least have a full and fair disclosure of all material facts relating to the amount, character and value of the property involved so that she will not be prejudiced by the lack of information, but can intelligently determine whether she desires to enter the prenuptial contract. +Juhasz v. Juhasz, supra; Warner v. Warner, supra; 2 +A. Lindey, § 90, at 44; 41 Am. Jur. 2d +Husband and VJife +§§ 313-14 +*303 +(1968). Viewed in the light of this test, we hold that plaintiff failed to sustain his burden of proof.

Further, the prospective spouse must sign the agreement freely and voluntarily on +independent advice +with full knowledge of her rights. +Hamlin v. Merlino, supra +at 864; 2 A. Lindey, § 90, at 36-38. It is clear that defendant did not have such advice prior to signing the agreement. All advice was provided by the plaintiff, his brother, Paul, and Mr. Monheimer. The prenuptial contract was even prepared by another of plaintiff’s attorneys.

The prenuptial agreement was void in its inception.

Plaintiff contends that the trial court’s error did not affect the distribution of property and, thus, is not fatal to the result. He argues that, contrary to defendant’s assertion, the trial court did not distribute the property pursuant to the prenuptial agreement, but relied instead upon RCW 26.08.110.

We disagree. RCW 26.08.110 provides that +all +property, +both community and separate, +shall be before the court for such distribution as may be +just and equitable. +Nevertheless, distribution in the instant case was virtually the same as that provided for in the prenuptial agreement and was overly disproportionate.

We agree with defendant, that the trial court treated the prenuptial agreement as binding upon the parties. The trial court’s oral opinion reflects its reliance on that contractual relationship by stating “we have to accept the agreement as it stands”. This coincides with finding of fact 12 in which the trial court found that she was bound by the agreement. The finding of fact was more than a mere statement that defendant was bound by a failure of proof. It was a finding that her rights in the distribution of property were governed by the prenuptial agreement.

The trial court erred by distributing the assets pursuant to a void prenuptial agreement.

*304 +IV

The Determination of Community' and Separate Property

Defendant argues that the trial court incorrectly classified virtually all assets as plaintiff’s separate property. She asserts further that there was a commingling of plaintiff’s separate property with community assets and that : the court should have imposed a lien upon the plaintiff’s separate property in behalf of the community.

Finding of fact 5 designates the plaintiff’s separate property and declares that it was identifiable, separately .maintained and not commingled with community property. Although there is, some conflict in the testimony, careful review of the record reveals substantial evidence to support the finding of fact. A trial court’s finding of fact must be accepted as a verity where there is substantial evidence to support it. +Friedlander v. Friedlander, +58 Wn.2d 288, 362 P.2d 352 (1961).

Similarly, conclusion of law 6 must be upheld. It is adequately supported by findings of fact 4 and 5. +State v. Russell, +73 Wn.2d 903, 910, 442 P.2d 988 (1968); +York v. Cooper, +60 Wn.2d 283, 286, 373 P.2d 493 (1962).

V

The Division of Separate and Community Assets

Although the trial court placed no specific value on plaintiff’s separate property, the record is clear that he received a disproportionate share of the total assets. Plaintiff attempts to justify this on the ground that in a divorce action the distribution of property made by a trial court may be overturned only for manifest abuse of discretion, .citing +Friedlander v. Friedlander, supra. +While the statement of the rule is correct, it is not applicable here.

The trial court did not exercise its discretion by distributing property pursuant to RCW 26.08.110. The disproportionate distribution was made because the trial court as +*305 +sumed it was bound by the void prenuptial contract. In short,, it is the distribution .pursuant to a void contract that is under attack and not the trial qourt’s power to distribute property pursuant to statutory discretion.

It was argued orally, and suggested in plaintiff’s brief, that in the final analysis distribution by the prenuptial contract essentially followed the law. We disagree. Granted, it followed that portion of RCW 26.08.110 which provides that the trial court shall consider “the party through whom the property was acquired”. This, however, is only one portion of the statutory requirements.

In an action for divorce +all property, +both community and separate, is before the trial court for distribution. +Patrick v. Patrick, +43 Wn.2d 139, 260 P.2d 878 (1953). Its characterization as community, or separate, though significant, is not necessarily controlling. +Huff v. Huff, +68 Wn.2d 501, 413 P.2d 818 (1966). RCW 26.08.110 requires a +just and equitable distribution +of the property. This does not entail an equal division thereof. +Ovens v. Ovens, +61 Wn.2d 6, 376 P.2d 839 (1962). Where children are not involved, RCW 26.08.110 requires that the trial court consider the following matters in achieving a just and equitable distribution: (1) the respective merits of the parties; (2) the condition in which they will be left by such divorce; and (3) the party through whom the property was acquired.

We have held that the trial court should also consider other factors. First, the court must consider the necessities of the wife and the financial ability of the husband. Then, it should take into account the age of the parties, their health, physical condition, education, their employment history. +DeRuwe v. DeRuwe, +72 Wn.2d 404, 408, 433 P.2d 209 (1967). It should likewise consider their training and business or occupation experience +(Stacy v. Stacy, +68 Wn.2d 573, 414 P.2d 791 (1966)), as well as their future earning prospects. +DeRuwe v. DeRuwe, supra. +The court should give regard to the date the parties accumulated the property, the party through whom it was acquired, the kinds of property involved +(DeRuwe v. De- +*306 +Ruwe, supra), as well as the value of the parties’ respective contribution to the community. +See VanKleffens v. VanKleffens, +150 Wash. 685, 274 P. 708 (1929). Even when regard is had for the fault of the parties +3 +and the wrong inflicted by one upon the other, the economic condition in which the decree will leave them remains the paramount concern in making a division of the property. +DeRuwe v. DeRuwe, supra.

The cause is remanded for the trial court to make a just and equitable division of the property of the parties in light of the foregoing guidelines and without regard to the void prenuptial agreement.

To insure an equitable distribution, it will be necessary for the trial court to make a valuation of all properties, whether community or separate.

The judgment is affirmed in part and reversed in part.

Hamilton, C. J., Finley, Rosellini, Hunter, Hale, Neill, and Wright, JJ., concur.

1

In this regard, +see +2 A. Lindey, Separation Agreements and Ante-Nuptial Contracts § 90, at 73-74 (rev. ed. 1967) wherein it is pointed out that prenuptial contracts which permit parties to separate at any time, or are made in contemplation of divorce, or purport to limit a husband’s liability for support in case of divorce, or are conducive of divorce are contrary to public policy and void. Arrangements suitable for a separation agreement cannot generally be incorporated in a prenuptial contract. +See also, +1 W. Nelson, Divorce and Annulment §§ 13.03, 13.06, 13.22 (2d ed. 1945); 41 Am. Jur. 2d +Husband and Wife +§ 279 (1968); Annot., 57 A.L.R.2d 942 (1958); Cathey, +Ante-Nuptial Agreements in Arkansas +— A +Drafter’s Problem, +24 Ark. L. Rev. 275, 287-88 (1970).

2

See also +Hamlin v. Merlino, +44 Wn.2d 851, 865, 272 P.2d 125 (1954); +Hartz v. Hartz, +248 Md. 47, 234 A.2d 865 (1967); +Kosik v. George, +253 Ore. 15, 452 P.2d 560 (1969); +Warner v. Warner, +235 Ill. 448, 85 N.E. 630 (1908); 2 A. Lindey, § 90, at 238 (Supp. 1971); 41 Am. Jur. 2d +Husband and Wife +§ 314 (1968).

3

For the consideration that should be given fault in the matter of distribution see +Bryant v. Bryant, +68 Wn.2d 97, 411 P.2d 428 (1966) and +Myers v. Myers, +21 Wn.2d 19, 23, 149 P.2d 926 (1944).

Case-law data current through December 31, 2025. Source: CourtListener bulk data.

↑ + \ No newline at end of file diff --git a/.research/friedlander.txt b/.research/friedlander.txt new file mode 100644 index 0000000..996a0e0 --- /dev/null +++ b/.research/friedlander.txt @@ -0,0 +1 @@ +Friedlander v. Friedlander, 494 P.2d 208 (Wash. 1972) | HallApproved.com Hall Approved Free Access to American Case Law Statutes Free Legal Archive / Washington / Cases / Washington Supreme Court / 1972 / Washington Supreme Court, 1972 Copy citation Free Legal Archive / Washington / Cases / Washington Supreme Court / 1972 / Friedlander v. Friedlander Friedlander v. Friedlander Washington Supreme Court · Decided February 24, 1972 · Stafford 494 P.2d 208; 80 Wash. 2d 293; 1972 Wash. LEXIS 586 (Pacific Reporter, Second Series) Friedlander v. Friedlander Opinion Stafford, J. Mr. John M. Friedlander (hereafter called the plaintiff) instituted an action for divorce against his wife, Polly (hereafter called the defendant). Defendant also sought a divorce from plaintiff. Each was granted a *295 divorce. Defendant was awarded substantially all community property whereas plaintiff received his own separate property. Defendant appeals. In 1955, defendant, a divorcee, began an affair with the plaintiff that lasted for approximately 5 years. Plaintiff’s then wife became acutely aware of the situation and, after a bitterly contested action in 1960, dissolved a marriage of 27 years standing. Much of plaintiff’s separate property, involved in this appeal, formed the subject of a similar appeal in Friedlander v. Friedlander, 58 Wn.2d 288 , 362 P.2d 352 (1961). Immediately following the divorce from Elizabeth, plaintiff and defendant discussed marriage. However, having just experienced one unpleasant dispute over property, plaintiff suggested that he and defendant enter into a prenuptial agreement. Essentially, the agreement provided that separate property owned by either party prior to the contemplated marriage would remain separate property, together with all rents, issues and profits therefrom. It specifically mentioned that plaintiff’s separate property consisted “principally of his holdings in the various Friedlander family enterprises and his contingent interest in the trust estate of Louis Friedlander, deceased.” Defendant agreed, in the event of a divorce, to “make no claim in any proceedings for any of the separate property of John M. Friedlander, or the rents, issues and profits thereof.” Although not specified in the prenuptial agreement, the “Friedlander family enterprises” in 1960 consisted of Friedlander and Sons, a corporation, which owned and operated a number of jewelry stores; LouBelle Realty Co., a corporation which owned land upon which the Logan Building was erected; P & J Wholesale Jewelers, a co-partnership; the Merton-Singerman Agency, a co-partnership; and the trust estate of Louis Friedlander, deceased. The parties were married 2 days after signing the prenuptial agreement. At the time defendant had virtually no *296 separate property and she acquired none during the marriage. The parties acquired a relatively small amount of community property. They lived on plaintiff’s salary which ranged from approximately $26,000 in 1960 to about $47,000 in 1969. Plaintiff derived other income from profits of the various “Friedlander family enterprises” and from the investment in securities which were his separate property. No children were born during the marriage. Defendant furthered her education during the ensuing years and completed all but two quarters for her fine arts degree. Unfortunately, the same period produced marital discord. Finally, each sought a divorce from the other claiming “cruel and inhuman treatment.” At the beginning of the marriage, the owners’ interest in the various “Friedlander family enterprises” was valued at about $1,041,183, approximately one-third of which belonged to plaintiff. When the marriage was dissolved in 1970, the owners’ equity had increased to approximately $1,297,243. Plaintiff’s share therein had been substantially increased by the death of his mother. The trial court granted each party a divorce. Plaintiff was awarded the community’s interest in the profit sharing trust of Friedlander and Sons, Inc., and all of his separate property which the court listed as his interest in Friedlan-der and Sons, Inc.; LouBelle Realty; P & J Wholesale Jewelry; Merton-Singerman Agency; an interest in the Louis Friedlander trust; an inheritance from his mother; and, his interest in various life insurance policies that had been owned prior to the marriage. In short, plaintiff’s share was essentially that provided for in the prenuptial agreement. Defendant was awarded most of the community property, which consisted of the family home and household furnishings; four vacant lots; the proceeds of a savings account and an automobile, all of which had a net value of about $32,000. She was also awarded alimony of $500 a month for 3 years, together with costs and attorneys’ fees. *297 Defendant appeals making 10 assignments of error which raise five basic issues. I The Husband’s Entitlement to Divorce for Mental Cruelty Defendant asserts that she alone was entitled to a decree of divorce based upon cruel and inhuman treatment. The assignment of error is not well taken. When two parties have sued for divorce on similar grounds, an appellant will not be heard to claim that the trial court erred by granting a divorce to the other spouse as well. Akins v. Akins, 51 Wn.2d 887 , 322 P.2d 872 (1958). In such a case, error, if any, is not prejudicial. II The Adequacy of Alimony Defendant asserts that prior to marriage she worked to support herself and child and lived in modest circumstances. In contrast, she contends, the marriage introduced her to a higher standard of living to which she has now become accustomed. She argues that she will be unable to maintain that standard. Thus, it is said, the trial court abused its discretion by granting her alimony of only $500 a month for 3 years. While this is an engaging argument, it is not a proper basis for awarding alimony. Morgan v. Morgan, 59 Wn.2d 639 , 369 P.2d 516 (1962). Alimony is not a matter of right. Kelso v. Kelso, 75 Wn.2d 24, 27 , 448 P.2d 499 (1968). It is based upon two factors: (1) the necessities of the wife and (2) the financial ability of the husband to pay. Kelso v. Kelso, supra; Murray v. Murray, 26 Wn.2d 370, 378 , 174 P.2d 296 (1946). The maintenance of a lifestyle to which one has become accustomed is not a test of need. Morgan v. Morgan, supra. Further, defendant’s child by a previous marriage is no *298 longer dependent upon her for support. Defendant is only 40 years of age. She assigns no error to the trial court’s findings of fact that she is in good health; that she is within two quarters of completing her fine arts degree at the University of Washington; and that she is capable of earning her own living. The record also reveals that she is engaged in the commercial operation of an art gallery which, according to her brief, is “a business for which her education and abilities give her qualifications . . .” The indication is that the prospect for the business is good, although it may take some time to establish the gallery’s name. We cannot say that the trial court abused its discretion either in the amount or the duration of the alimony. Abuse of discretion is not shown -unless the discretion has been exercised upon a ground, or to an extent, clearly untenable or manifestly unreasonable. Malfait v. Malfait, 54 Wn.2d 413 , 341 P.2d 154 (1959); High v. High, 41 Wn.2d 811 , 252 P.2d 272 (1953); Berol v. Berol, 37 Wn.2d 380 , 223 P.2d 1055 (1950). See also State ex rel. Beffa v. Superior Court, 3 Wn.2d 184 , 100 P.2d 6 (1940). Defendant has failed to demonstrate the requisite need for additional funds. Ill The Prenuptial Agreement Both parties, as well as the trial court, have characterized the questioned instrument as a “prenuptial agreement.” In citing Hamlin v. Merlino, 44 Wn.2d 851 , 272 P.2d 125 (1954), each party has also referred to it as an “antenuptial” agreement. However, these two designations are synonymous and the parties have so treated them. 2 A. Lindey, Separation Agreements' and Ante-Nuptial Contracts § 90, at 22-23 (rev. ed. 1967). It is significant that the transaction involves a prenuptial agreement as distinguished from a postnuptial or separation agreement and that it has been so treated by the parties and the trial court as well. A prenuptial agreement is one entered into by prospective spouses prior to marriage *299 but in contemplation and in consideration thereof. By it, the property rights of one or both of the prospective spouses are determined or are secured to one or both of them or to their children. On the other hand, postnuptial agreements or settlements are made after marriage between couples still married. They take the form of (a) separation agreements; (b) property settlements in contemplation of a separation or divorce; (c) property settlements where there is no intention of the parties to separate. 2 A. Lindey, § 90, at 22-23; 1 W. Nelson, Divorce and Annulment § 13.02, at 485 (2d ed. 1945). It is also important that although defendant challenges the validity of the prenuptial agreement, based upon the conditions that surrounded its making, neither party contends that prenuptial contracts, as such, are contrary to public policy, if freely and intelligently made. Hamlin v. Merlino, supra; 2 A. Lindey, § 90, at 30; see also 1 W. Nelson, § 13.03; 41 Am. Jur. 2d Husband and Wife § 283 (1968). Finally, neither party raises the question whether the prenuptial agreement was made in contemplation of or is promotive of divorce, and if so, whether it is void as against public policy for that reason. 1 Thus, there is no need to resolve either of the immediately preceding questions in this case. We are here concerned with whether the prenuptial agreement, assuming its proper use in this type of transaction, is valid as between these parties under the rules governing prenuptial agreements. First, defendant argues that there was no considera *300 tion for the agreement because plaintiff had previously proposed marriage. This position, however, finds no support in the authorities. Marriage is not only, adequate, but is consideration of the highest value. 2 A. Lindey, § 90, at 32-33; 41 Am. Jur. 2d Husband and Wife § 285, at 235 ,(1968); In re Estate of Onstot, 224 Iowa 520 , 277 N.W. 563 (1938); see also 1 W. Nelson, § 13.03. Further, the agreement contained mutual waivers by the parties. This also is adequate consideration for a prenuptial agreement. 2 A. Lindey, § 90, at 34; 41 Am. Jur. 2d Husband and Wife § 285, at 235 (1968). Next, defendant contends the trial court erred by finding: “. . . Polly Friedlander has not sustained the burden of proving that the [prenuptial] agreement was not executed in good faith . . .” (Italics ours.) The finding of fact was proposed by plaintiff’s attorney. However, during oral argument he conceded that it incorrectly shifted, to defendant, the burden of proving the prenuptial agreement was not executed in good faith. Obviously, counsel's concession has placed the trial court in an awkward position. Nevertheless, it comports with the law relative to prenuptial agreements. Generally speaking, the burden of establishing full disclosure or fairness rests upon the party asserting the prenuptial agreement (i.e., the plaintiff husband herein). 2 A. Lindey, § 90, at 38 and 85; 41 Am. Jur. 2d Husband and Wife § 313, at 254 (1968). As stated in 2 A. Lindey, § 90, at 84: where the provision made for the wife is disproportionate to the property of the husband, a presumption arises that the contract was procured by deliberate concealment of the amount and value of the husband’s property; and the husband or those claiming under him against the wife have the burden of showing that she had full knowledge of the value of her interest in the husband’s property, or that the circumstances were such that she reasonably should have had such knowledge.[ 2 ] *301 The trial court erred by finding that defendant had the burden of proving the agreement was not executed in good faith. A prenuptial agreement freely and intelligently made is generally regarded as conducive to marital tranquility and the avoidance of disputes about property in the future. 2 A. Lindey, § 90, at 30. For that reason, it is regarded with favor. But, the beneficial possibilities of such contracts must be preserved without the attendant dangers of abuse. With this in mind the relationship of the parties to the contract becomes of primary importance. It is well recognized that even an engagement to marry creates a confidential relationship. Hamlin v. Merlino, 44 Wn.2d 851, 865 , 272 P.2d 125 (1954); Juhasz v. Juhasz, 134 Ohio St. 257, 264 , 16 N.E.2d 328 , 117 A.L.R. 993 (1938). Parties to a prenuptial agreement do not deal with each other at arm’s length. Their relationship is one of mutual confidence and trust which calls for the exercise of good faith, candor and sincerity in all matters bearing upon the proposed agreement. Bauer v. Bauer, 1 Ore. App. 504 , 464 P.2d 710 (1970); 2 A. Lindey, § 90, at 38, 41. The basic objective of this common sense rule is to prevent overreaching. 2 A. Lindey, § 90, at 240 (Supp. 1971). Where a prenuptial contract makes provision for a wife that is disproportionate to the means of the intended husband, it casts a burden upon the intended husband, and those claiming under him, to prove that she had full knowledge of all the facts and circumstances that materially affected the contract. Juhasz v. Juhasz, supra; Warner v. Warner, 235 Ill. 448, 462 , 85 N.E. 630 (1908). Without question, the record in this case discloses that the prenuptial contract makes provision for the wife that is disproportionate to the means of the husband. Plaintiff acknowledges that the establishment of good faith and full disclosure is his burden. However, he asserts that he has sustained it. He argues that he told defendant he had had many difficulties during the first divorce that he *302 did not want to encounter again. Plaintiff asserts that the agreement itself discloses the nature of the assets by referring to “property and assets, consisting primarily of his holdings in the various Friedlander family enterprises and his contingent interest in the trust estate of Louis Friedlan-der, deceased.” It is related that both Mr. Monheimer, an attorney for plaintiff and for the Friedlander family, and plaintiff’s brother, Paul (also an attorney), informed defendant generally of the nature and effect of a prenuptial agreement. Plaintiff indicated that defendant signed the agreement without objection, knowing that it involved property consisting of jewelry stores and the Logan Building realty. It must be observed, however, that the statement of facts fails to reveal the content of any explanation made by Mr. Monheimer or Mr. Paul Friedlander. In fact, neither could have explained the substance of the actual agreement. At the time, it had not been drafted by Mr. Friedman, another of plaintiff’s attorneys. There is no evidence that defendant had anyone explain the contents of the written agreement to her. Finally, there is no evidence that anyone discussed with her the value of the property with which the prenuptial agreement was concerned. This brings us to the nature of the good faith disclosure required by a prenuptial agreement. To render such an agreement valid there must be a fair and reasonable provision for the wife, or, in the absence thereof there must be a full, frank disclosure of the future husband’s property and his worth. Juhasz v. Juhasz, supra; Warner v. Warner, supra; 2 A. Lindey, § 90, at 36-37. This is not to say that she must know the exact financial status of his resources. However, she must at least have a full and fair disclosure of all material facts relating to the amount, character and value of the property involved so that she will not be prejudiced by the lack of information, but can intelligently determine whether she desires to enter the prenuptial contract. Juhasz v. Juhasz, supra; Warner v. Warner, supra; 2 A. Lindey, § 90, at 44; 41 Am. Jur. 2d Husband and VJife §§ 313-14 *303 (1968). Viewed in the light of this test, we hold that plaintiff failed to sustain his burden of proof. Further, the prospective spouse must sign the agreement freely and voluntarily on independent advice with full knowledge of her rights. Hamlin v. Merlino, supra at 864; 2 A. Lindey, § 90, at 36-38. It is clear that defendant did not have such advice prior to signing the agreement. All advice was provided by the plaintiff, his brother, Paul, and Mr. Monheimer. The prenuptial contract was even prepared by another of plaintiff’s attorneys. The prenuptial agreement was void in its inception. Plaintiff contends that the trial court’s error did not affect the distribution of property and, thus, is not fatal to the result. He argues that, contrary to defendant’s assertion, the trial court did not distribute the property pursuant to the prenuptial agreement, but relied instead upon RCW 26.08.110. We disagree. RCW 26.08.110 provides that all property, both community and separate, shall be before the court for such distribution as may be just and equitable. Nevertheless, distribution in the instant case was virtually the same as that provided for in the prenuptial agreement and was overly disproportionate. We agree with defendant, that the trial court treated the prenuptial agreement as binding upon the parties. The trial court’s oral opinion reflects its reliance on that contractual relationship by stating “we have to accept the agreement as it stands”. This coincides with finding of fact 12 in which the trial court found that she was bound by the agreement. The finding of fact was more than a mere statement that defendant was bound by a failure of proof. It was a finding that her rights in the distribution of property were governed by the prenuptial agreement. The trial court erred by distributing the assets pursuant to a void prenuptial agreement. *304 IV The Determination of Community' and Separate Property Defendant argues that the trial court incorrectly classified virtually all assets as plaintiff’s separate property. She asserts further that there was a commingling of plaintiff’s separate property with community assets and that : the court should have imposed a lien upon the plaintiff’s separate property in behalf of the community. Finding of fact 5 designates the plaintiff’s separate property and declares that it was identifiable, separately .maintained and not commingled with community property. Although there is, some conflict in the testimony, careful review of the record reveals substantial evidence to support the finding of fact. A trial court’s finding of fact must be accepted as a verity where there is substantial evidence to support it. Friedlander v. Friedlander, 58 Wn.2d 288 , 362 P.2d 352 (1961). Similarly, conclusion of law 6 must be upheld. It is adequately supported by findings of fact 4 and 5. State v. Russell, 73 Wn.2d 903, 910 , 442 P.2d 988 (1968); York v. Cooper, 60 Wn.2d 283, 286 , 373 P.2d 493 (1962). V The Division of Separate and Community Assets Although the trial court placed no specific value on plaintiff’s separate property, the record is clear that he received a disproportionate share of the total assets. Plaintiff attempts to justify this on the ground that in a divorce action the distribution of property made by a trial court may be overturned only for manifest abuse of discretion, .citing Friedlander v. Friedlander, supra. While the statement of the rule is correct, it is not applicable here. The trial court did not exercise its discretion by distributing property pursuant to RCW 26.08.110. The disproportionate distribution was made because the trial court as *305 sumed it was bound by the void prenuptial contract. In short,, it is the distribution .pursuant to a void contract that is under attack and not the trial qourt’s power to distribute property pursuant to statutory discretion. It was argued orally, and suggested in plaintiff’s brief, that in the final analysis distribution by the prenuptial contract essentially followed the law. We disagree. Granted, it followed that portion of RCW 26.08.110 which provides that the trial court shall consider “the party through whom the property was acquired”. This, however, is only one portion of the statutory requirements. In an action for divorce all property, both community and separate, is before the trial court for distribution. Patrick v. Patrick, 43 Wn.2d 139 , 260 P.2d 878 (1953). Its characterization as community, or separate, though significant, is not necessarily controlling. Huff v. Huff, 68 Wn.2d 501 , 413 P.2d 818 (1966). RCW 26.08.110 requires a just and equitable distribution of the property. This does not entail an equal division thereof. Ovens v. Ovens, 61 Wn.2d 6 , 376 P.2d 839 (1962). Where children are not involved, RCW 26.08.110 requires that the trial court consider the following matters in achieving a just and equitable distribution: (1) the respective merits of the parties; (2) the condition in which they will be left by such divorce; and (3) the party through whom the property was acquired. We have held that the trial court should also consider other factors. First, the court must consider the necessities of the wife and the financial ability of the husband. Then, it should take into account the age of the parties, their health, physical condition, education, their employment history. DeRuwe v. DeRuwe, 72 Wn.2d 404, 408 , 433 P.2d 209 (1967). It should likewise consider their training and business or occupation experience (Stacy v. Stacy, 68 Wn.2d 573 , 414 P.2d 791 (1966)), as well as their future earning prospects. DeRuwe v. DeRuwe, supra. The court should give regard to the date the parties accumulated the property, the party through whom it was acquired, the kinds of property involved (DeRuwe v. De- *306 Ruwe, supra), as well as the value of the parties’ respective contribution to the community. See VanKleffens v. VanKleffens, 150 Wash. 685 , 274 P. 708 (1929). Even when regard is had for the fault of the parties 3 and the wrong inflicted by one upon the other, the economic condition in which the decree will leave them remains the paramount concern in making a division of the property. DeRuwe v. DeRuwe, supra. The cause is remanded for the trial court to make a just and equitable division of the property of the parties in light of the foregoing guidelines and without regard to the void prenuptial agreement. To insure an equitable distribution, it will be necessary for the trial court to make a valuation of all properties, whether community or separate. The judgment is affirmed in part and reversed in part. Hamilton, C. J., Finley, Rosellini, Hunter, Hale, Neill, and Wright, JJ., concur. 1 In this regard, see 2 A. Lindey, Separation Agreements and Ante-Nuptial Contracts § 90, at 73-74 (rev. ed. 1967) wherein it is pointed out that prenuptial contracts which permit parties to separate at any time, or are made in contemplation of divorce, or purport to limit a husband’s liability for support in case of divorce, or are conducive of divorce are contrary to public policy and void. Arrangements suitable for a separation agreement cannot generally be incorporated in a prenuptial contract. See also, 1 W. Nelson, Divorce and Annulment §§ 13.03, 13.06, 13.22 (2d ed. 1945); 41 Am. Jur. 2d Husband and Wife § 279 (1968); Annot., 57 A.L.R.2d 942 (1958); Cathey, Ante-Nuptial Agreements in Arkansas — A Drafter’s Problem, 24 Ark. L. Rev. 275 , 287-88 (1970). 2 See also Hamlin v. Merlino, 44 Wn.2d 851, 865 , 272 P.2d 125 (1954); Hartz v. Hartz, 248 Md. 47 , 234 A.2d 865 (1967); Kosik v. George, 253 Ore. 15 , 452 P.2d 560 (1969); Warner v. Warner, 235 Ill. 448 , 85 N.E. 630 (1908); 2 A. Lindey, § 90, at 238 (Supp. 1971); 41 Am. Jur. 2d Husband and Wife § 314 (1968). 3 For the consideration that should be given fault in the matter of distribution see Bryant v. Bryant, 68 Wn.2d 97 , 411 P.2d 428 (1966) and Myers v. Myers, 21 Wn.2d 19, 23 , 149 P.2d 926 (1944). Case-law data current through December 31, 2025. Source: CourtListener bulk data . A public interest project of Aaron Hall, Attorney at Law © 2026 About Federal Minnesota California New York Texas Terms Data from CourtListener / Free Law Project ↑ \ No newline at end of file diff --git a/.research/hall.html b/.research/hall.html new file mode 100644 index 0000000..59d74f7 --- /dev/null +++ b/.research/hall.html @@ -0,0 +1,176 @@ +In Re the Marriage of Hall, 692 P.2d 175 (Wash. 1984) | HallApproved.com
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Washington Supreme Court, 1984 +

In Re the Marriage of Hall

In Re the Marriage of Hall
Washington Supreme Court · Decided December 13, 1984 · Brachtenbach
692 P.2d 175; 103 Wash. 2d 236; 1984 Wash. LEXIS 2098 +(Pacific Reporter, Second Series)

In Re the Marriage of Hall

Opinion

Brachtenbach, J.

Did the trial court err in this dissolution action in finding that the husband, a medical doctor in private practice, possessed goodwill valued at $70,000, but that the wife, a medical doctor employed as a salaried professor, did not possess goodwill? Secondarily, did the trial court apply the proper factors in valuing the husband's goodwill? By an unpublished split decision, the Court of Appeals affirmed. +In re Marriage of Hall, +36 Wn. App. 1026 (1983). We reverse in part and remand for further proceedings.

Judith G. Hall, M.D., and Phillip L. Hall, M.D., were married in 1963 while medical school students. In 1966 both received their medical doctorates, served internships and pursued specialized training — Judith in pediatrics and Phillip in cardiology. Returning to Seattle in 1972, Judith was hired by the University of Washington Medical School as an assistant professor. Phillip entered private practice as +*238 +an internist employed by a private clinic.

At the time of trial, Phillip, age 41, enjoyed a good reputation in the community as a consulting cardiologist. In 1975, Phillip and another doctor formed a partnership, which was incorporated in 1977 as Northwest Cardiology Clinic. A third doctor became a shareholder in 1979. Three hospitals, as well as other doctors, referred patients to the clinic which was located on the campus of one of the hospitals. In the 3 years preceding trial, Phillip's average gross yearly earnings, exclusive of retirement contributions, were $52,411.83.

Judith, age 40 at the time of trial, was an untenured professor at the University of Washington with no expectation of tenure in the foreseeable future. In the 3 years preceding trial, Judith's average gross yearly earnings, exclusive of employer contributions to her retirement plan, were $32,750. In mid-1980 her salary increased to $42,000. Judith testified that her decision to pursue an academic career was primarily attributable to the need for a flexible schedule in order to care for the Halls' children. Although Judith is widely published and enjoys a reputation as one of the 10 top physicians in the nation in the field of pediatric genetics, there are few, if any, medical career opportunities outside academia, especially in the Seattle area. Numerous medical schools across the nation have offered her employment with salaries up to $60,000. Employment opportunities outside of academia with salaries in the range of $50,000 could be available with some retraining and relocation.

The trial court found that Judith had no professional goodwill due to the fact that she was a salaried physician. The court found that Phillip had professional goodwill in the amount of $70,000. A decree of dissolution was entered accordingly. The Court of Appeals affirmed the trial court's holdings; Phillip Hall petitioned for review.

Evaluation of professional goodwill is a troublesome issue. Since 1976, professional goodwill has been recognized in Washington as property of an intangible nature subject +*239 +to division in a marriage dissolution. +In re Marriage of Lukens, +16 Wn. App. 481, 558 P.2d 279 (1976). It is often defined as the "expectation of continued public patronage". +Lukens, +at 483. Justice Story has more thoroughly defined professional goodwill as:

a benefit or advantage "which is acquired by an establishment beyond the mere value of the capital, stock, funds or property employed therein, in consequence of the general public patronage and encouragement, which it receives from constant or habitual customers on account of its local position, or common celebrity, or reputation for skill or affluence, or punctuality, or from other accidental circumstances or necessities, or even from ancient partialities or prejudices."

Lukens, +at 483-84, citing +In re Marriage of Foster, +42 Cal. App. 3d 577, 117 Cal. Rptr. 49 (1974).

In 1979, reviewing the decisions of other courts, this court noted that a number of states had refused, in a divorce proceeding, to assign a value to goodwill of a professional practice, but adopted the +Lukens +recognition of goodwill as a marital asset. +In re Marriage of Fleege, +91 Wn.2d 324, 588 P.2d 1136 (1979). In +Fleege, +the issue was whether the goodwill of the husband's solo dental practice was a community asset. Despite expert testimony establishing that the value of his dental practice included goodwill, the trial court had refused to include goodwill as an asset subject to distribution. This court held that, although professional goodwill is not readily salable, the important consideration is not whether the goodwill of the practice could be sold without the personal services of the professional, but whether it has value to him. +Fleege, +at 327. The dissent contended that goodwill is not a marital asset subject to division because no true goodwill could exist separate and apart from the services of the practitioner. +Fleege, +at 330-36 (Stafford, J., dissenting).

Since +Fleege, +this court has not ruled further on the concept of goodwill. The Court of Appeals, however, applied the principles of +Fleege +to a case involving a lawyer in solo practice. +In re Marriage of Freedman, +23 Wn. App. 27, 592 +*240 +P.2d 1124 (1979) +(Freedman +I). In +Freedman +I, the trial court had included the lawyer's goodwill, valued at $100,000, in the community assets to be distributed. While adhering to +Fleege, +the Court of Appeals nevertheless remanded the case so that further testimony could be taken on all the factors set forth in +Fleege. +Although the existence of goodwill was not then at issue, the trial court, upon remand, found that goodwill could not exist in a solo law practice because it could not be sold. Instead, the trial court awarded the wife $19,451 as her "spouse's economic benefit expectancy" (SEBE). On a second appeal, the Court of Appeals did not analyze the nature of SEBE, nor did it consider the correctness of the trial court's finding of lack of goodwill. +In re Marriage of Freedman, +35 Wn. App. 49, 51, 665 P.2d 902 (1983) +(Freedman +II). The Court of Appeals held that regardless of the name given, the trial court had considered the +Fleege +factors as required in +Freedman +I. Therefore, the award to the wife as SEBE was affirmed.

The last case to discuss professional goodwill was +In re Marriage of Kaplan, +23 Wn. App. 503, 597 P.2d 439 (1979), which involved an attorney who was a "special partner" in a law firm. The trial court found that attorneys in general do not possess goodwill as an item of property. Alternatively, it found that even if attorneys in general do have goodwill, Mr. Kaplan did not. Relying on +Freedman +I, the Court of Appeals held that the legal question of whether an attorney has goodwill was foreclosed. The +Kaplan +court reversed and remanded for consideration of those factual elements used in determining the value of goodwill as discussed in +Fleege +and +Freedman +I.

The husband here contends that the +Fleege +doctrine should be reconsidered because (1) it presents confusing and unfair criteria for identifying and evaluating the economic benefit to one spouse or the other, from a professional degree and career; and, (2) it is unfair where, as here, it requires the determination that only one of two spouses, with identical professional educations and earning capaci +*241 +ties, has professional goodwill. These contentions are based on the failure to distinguish between professional goodwill and personal earning capacity of the professional.

Goodwill is a property or asset which usually supplements the earning capacity of another asset, a business or a profession. Goodwill is not the earning capacity itself. It is a distinct +asset +of a professional practice, not just a +factor +contributing to the value or earning capacity of the practice. Comment, +Professional Goodwill in Louisiana: An Analysis of its Classification, Valuation, and Partition, +43 La. L. Rev. 119, 123 (1982); 38 Am. Jur. 2d +Good Will +§ 8, at 916 (1968). Discontinuance of the business or profession may greatly diminish the value of the goodwill but it does not destroy its existence. When a professional retires or dies, his earning capacity also either retires or dies. Nevertheless, the goodwill that once attached to his practice may continue in existence in the form of established patients or clients, referrals, trade name, location and associations which now attach to former partners or buyers of the practice. Comment, +Identifying, Valuing, and Dividing Professional Goodwill as Community Property at Dissolution of the Marital Community, +56 Tul. L. Rev. 313, 320 (1981). Reference to Judge Reed's example in +Lukens, +at 485, illustrates the difference in that a professional can transport all of his skill (earning capacity) to a new town, but patients or clients, reputation and referrals (goodwill) cannot always be transported.

Once goodwill is distinguished from earning capacity, the error becomes apparent in the argument that a practicing professional and a salaried professional, with equal earning capacities and educations, both have goodwill. Both have earning capacities, and, yet, only the practicing professional has a business or practice to which the goodwill can attach. The practicing professional brings an earning capacity to the practice comprised of skill and education. The goodwill, comprised of such things as location, referrals, associations, reputation, trade name and office organization, can directly supplement this earning capacity. +*242 +When the practicing professional dies, retires or moves, he takes his skill and education with him, but the goodwill factors must be transferred or otherwise left behind. The goodwill may exist even though it is not marketable. +In re Marriage of Freedman, +23 Wn. App. 27, 592 P.2d 1124 (1979).

The salaried professional also brings an earning capacity comprised of skill and education to the position. However, when the salaried professional leaves a position, he takes everything with him to the new position. There is nothing that increased his earning capacity in the old salaried position that cannot be taken to the new position.

The Court of Appeals and petitioner's expert witnesses distinguished between goodwill and earning capacity when they recognized that, by definition, a person working solely for a salary as an employee has no goodwill. We adopt the Court of Appeals holding and hold that as a matter of law a salaried employee such as Judith Hall cannot have goodwill.

We turn now to the matter of Phillip Hall's goodwill. When the Court of Appeals first recognized that the practice of a professional may include goodwill it looked to the California courts for guidance. The Court of Appeals in +In re Marriage of Lukens, +16 Wn. App. 481, 558 P.2d 279 (1976) and the Supreme Court in +In re Marriage of Fleege, +91 Wn.2d 324, 588 P.2d 1136 (1979) adopted both the holding of +In re Marriage of Lopez, +38 Cal. App. 3d 93, 113 Cal. Rptr. 58 (1974) and the factors set out by that court for valuation of the goodwill. The factors: the practitioner's age, health, past demonstrated earning power, professional reputation in the community as to his judgments, skill, knowledge and his comparative professional success, have become known as the +Fleege +factors. Two areas surrounding the +Fleege +factors must be clarified: (1) the first step in evaluation under the +Fleege +factors is the determination of the existence of goodwill and (2) several accounting or appraisal methods may be used by the trial court in conjunction with the +Fleege +factors.

*243 +The +Lopez +court warned that evaluation of goodwill must be done with considerable care and caution. +Lopez, +at 110. In carrying out this warning the court instructed that the trial courts should first determine if goodwill exists in a particular practice. Not every professional business as a going concern necessarily has goodwill. +Lopez, +at 109. The Washington goodwill cases to date have not recognized this preliminary inquiry and we do so today. This preliminary inquiry takes place during the general evaluation process. The trial court must bear in mind throughout this process that there may be zero goodwill.

The +Fleege +factors, under which the determination of existence and evaluation are made, give little guidance to the trial courts. Although we continue to require their usage when appropriate, +i.e., +when those factors are present, during valuation of goodwill, we now recognize various methods which may be used in conjunction with these factors. The +Fleege +factors cannot be evaluated and valued in isolation. One or more of the accepted methods of valuation must be employed. The particular method used by the trial court will depend on the offered proof. Because evidence available to the court varies greatly from case to case, selection of any one method for all cases would unnecessarily limit the court in making a fair and just distribution.

In valuing goodwill five major formulas have been articulated. +See generally +Comment, +Identifying, Valuing, and Dividing Professional Goodwill as Community Property at Dissolution of the Marital Community, +56 Tul. L. Rev. 313 (1981); Comment, +The Recognition and Valuation of Professional Goodwill in the Marital Estate, +66 Marq. L. Rev. 697 (1983); Dlugatch & Olds, +Determining Goodwill in a Professional Practice for Purpose of a Community Property Division in a Marital Dissolution, +9 Community Prop. J. 120 (1982). There are three accounting formulas. Under the straight capitalization accounting method the average net profits of the practitioner are determined and this figure is capitalized at a definite rate, as, for example, 20 per +*244 +cent. This result is considered to be the total value of the business including both tangible and intangible assets. To determine the value of goodwill the book value of the business' assets are subtracted from the total value figure. +1

The second accounting formula is the capitalization of excess earnings method. Under the pure capitalization of excess earnings the average net income is determined. From this figure an annual salary of average employee practitioner with like experience is subtracted. The remaining amount is multiplied by a fixed capitalization rate to determine the goodwill. +2

The IRS variation of capitalized excess earnings method takes the average net income of the business for the last 5 years and subtracts a reasonable rate of return based on the business' average net tangible assets. From this amount a comparable net salary is subtracted. Finally, this remaining amount is capitalized at a definite rate. The resulting amount is goodwill. +3

The fourth method, the market value approach, sets a value on professional goodwill by establishing what fair price would be obtained in the current open market if the practice were to be sold. This method necessitates that a +*245 +professional practice has been recently sold, is in the process of being sold or is the subject of a recent offer to purchase. Otherwise, the value may be manipulated by the professional spouse.

The fifth valuation method, the buy/sell agreement method, values goodwill by reliance on a recent actual sale or an unexercised existing option or contractual formula set forth in a partnership agreement or corporate agreement. Since the professional spouse may have been influenced by many factors other than fair market value in negotiating the terms of the agreement, courts relying on this method should inquire into the presence of such factors, as well as the arm's length nature of the transaction.

These five methods are not the exclusive formulas available to trial courts in analyzing the evidence presented. Nor must only one method be used in isolation. One or more methods may be used in conjunction with the +Fleege +factors to achieve a just and fair evaluation of the existence and value of any professional's goodwill.

The danger of using any one method without regard to the +Fleege +factors is apparent in the present case where petitioner's expert witnesses used only the capitalized excess earnings approach. Under this approach the experts testified that Phillip had no goodwill. Further testimony, however, indicated that Phillip's comparatively low earnings were a result of office expansion expenses, a deliberate decision to limit hours of practice and failure to compare Phillip with cardiologists in the same age and experience group doing similar procedures in Seattle. Consideration of the petitioner's reputation, associations, referrals, location and trade name indicate the existence of goodwill.

This case also exemplifies the need for caution in the use of the buy/sell agreement. The Northwest Cardiology Clinic buy/sell agreement does not include a goodwill factor. When the third doctor became a shareholder, no value was assigned to goodwill. The trial court must, however, inquire whether the omission in the agreement was the result of other factors or deliberations on the part of the sharehold +*246 +ers, particularly when the particular agreement is made in close proximity in time to the divorce.

Although an analysis of the evidence suggests the existence of goodwill in Phillip's practice, there is insufficient evidence as to the court's valuation of $70,000. Valuation of goodwill is a question of fact, +Suther v. Suther, +28 Wn. App. 838, 627 P.2d 110, +review denied, +95 Wn.2d 1029 (1981). Findings of fact supported by substantial evidence in the record will not be reversed on appeal. +Trans-Canada Enters., Ltd. v. King Cy., +29 Wn. App. 267, 271, 628 P.2d 493, +review denied, +96 Wn.2d 1002 (1981). Substantial evidence is evidence sufficient to persuade a fair-minded person of the truth of the declared premise. +Smith v. Shannon, +100 Wn.2d 26, 666 P.2d 351 (1983); +Ridgeview Properties v. Starbuck, +96 Wn.2d 716, 638 P.2d 1231 (1982).

The trial court found that Phillip had goodwill in the amount of $70,000 "based on the court's evaluation of the factors involved in determining goodwill". The court failed, however, to indicate what factors and method were used in valuation and, in fact, noted in its oral ruling:

I am not going to go over all of my reasons. I have simply been persuaded that it exists in the consideration of the status of the practice.

Report of Proceedings, at 129.

The record with regard to Phillip Hall's goodwill consists of the testimony of petitioner's expert witnesses and Judith Hall, and the accounting records of Phillip's earnings and tangible business assets. Petitioner's experts, an accountant and an economist, testified that based solely on the capitalized excess earnings approach, Phillip has no goodwill. Judith testified that based on other dissolution actions involving physicians, Phillip's goodwill is at least $100,000. Judith's testimony was the only evidence which assigned value to Phillip's goodwill. Her value was not based upon any analysis or upon application of any recognized valuation methodology. Nonetheless, it came in without objection. We, therefore, express no opinion as to its admissibility.

*247 +The evidence set forth in the record is insufficient to support the finding that Phillip has $70,000 worth of goodwill. The unsubstantiated opinion of Judith and the records of Phillip's earnings and tangible assets are insufficient, without further analysis by the trial court, to persuade a fair-minded person that the $70,000 figure is the true value of Phillip's goodwill. The trial court must set forth on the record which factors and method were used in reaching its finding. We, therefore, reverse and remand for further findings by the trial court in accordance with the valuation guidelines set forth herein.

Petitioner also raises the issue of the proper method of analyzing the future earning potential that Judith Hall has gained during marriage. Petitioner contends that the increase in earning potential, as evidenced by Judith's numerous published writings, her excellent reputation in her field and recent job offers, is an asset so similar to goodwill that it should be considered to offset his goodwill.

Although treatment of future earning capacity as a distinct marital asset has been advocated, +see +Comment, +A Property Theory of Future Earning Potential in Dissolution Proceedings, +56 Wash. L. Rev. 277 (1981), this court has declined to treat it as such. Recently, we have emphasized future earning capacity as a factor to be considered in property distribution in the context of professional degrees. +In re Marriage of Washburn, +101 Wn.2d 168, 677 P.2d 152 (1984). In +Washburn, +we discussed a line of cases which view the professional degree (or the enhanced earning potential which it represents) as property, to be valued and distributed upon dissolution of marriage; as nonproperty, but as a factor deserving of a restitutionary award; as non-property to be considered in alimony; and as nonproperty deserving of no compensation. +Washburn, +at 174-75.

As we held in the context of professional degrees, we now hold that the provisions of our dissolution of marriage act, codified in RCW 26.09, provide for a fair and just treatment of future earning potential. RCW 26.09.080 reads in part:

*248 +In a proceeding for dissolution of the marriage, legal separation, . . . the court shall, without regard to marital misconduct, make such disposition of the property and the liabilities of the parties, either community or separate, as shall appear just and equitable after considering all relevant factors including, but not limited to:

(1) The nature and extent of the community property;

(2) The nature and extent of the separate property;

(3) The duration of the marriage; and

(4) The economic circumstances of each spouse at the time the division of property is to become effective, including the desirability of awarding the family home or the right to live therein for reasonable periods to a spouse having custody of any children.

In addition to the four subsections in RCW 26.09.080, which include "[t]he economic circumstances of each spouse at the time the division of property is to become effective," the court should also consider the age, health, education and employment history of the parties and their children, and the future earning prospects of all of them in determining a just and equitable division. +DeRuwe v. DeRuwe, +72 Wn.2d 404, 408, 433 P.2d 209 (1967); +In re Marriage of Rink, +18 Wn. App. 549, 551, 571 P.2d 210 (1977). In +Wash-burn +we also emphasized the importance of the future earning potential of each spouse by setting it out as one of four factors to be considered in determining the proper amount of compensation for the supporting spouse.

Once again we emphasize the importance of consideration of future earning potential. We decline to find that future earning potential is an asset which can be used to offset goodwill. Instead, we hold that it is a substantial factor to be considered by the trial court in making a just and equitable property distribution. On remand, the trial court should articulate its reasoning in taking into account this substantial factor.

Williams, C.J., Utter, Dolliver, Dore, Dimmick, and Pearson, JJ., and Cunningham, J. Pro Tern., concur.

1

Average net earnings $60,000

Capitalize at 20% x 5

Total business tangible and intangible assets 300,000

Less current net tangible assets -30,000

Goodwill $270,000

2

Average net earnings $60,000

Less comparable net salary —40,000

Average earnings on intangible assets 20,000

Capitalize at 20% x 5

Goodwill $109,000

3

Average net earnings $60,000

Less rate of return on average tangible assets -2,500

Subtotal $57,500

Less comparable net salary -40,000

Average earnings on intangible assets 17,500

Capitalize at 20% x 5

GoodwiU $87,500

Case-law data current through December 31, 2025. Source: CourtListener bulk data.

↑ + \ No newline at end of file diff --git a/.research/hall.txt b/.research/hall.txt new file mode 100644 index 0000000..bf3703d --- /dev/null +++ b/.research/hall.txt @@ -0,0 +1 @@ +In Re the Marriage of Hall, 692 P.2d 175 (Wash. 1984) | HallApproved.com Hall Approved Free Access to American Case Law Statutes Free Legal Archive / Washington / Cases / Washington Supreme Court / 1984 / Washington Supreme Court, 1984 Copy citation Free Legal Archive / Washington / Cases / Washington Supreme Court / 1984 / In Re the Marriage of Hall In Re the Marriage of Hall Washington Supreme Court · Decided December 13, 1984 · Brachtenbach 692 P.2d 175; 103 Wash. 2d 236; 1984 Wash. LEXIS 2098 (Pacific Reporter, Second Series) In Re the Marriage of Hall Opinion Brachtenbach, J. Did the trial court err in this dissolution action in finding that the husband, a medical doctor in private practice, possessed goodwill valued at $70,000, but that the wife, a medical doctor employed as a salaried professor, did not possess goodwill? Secondarily, did the trial court apply the proper factors in valuing the husband's goodwill? By an unpublished split decision, the Court of Appeals affirmed. In re Marriage of Hall, 36 Wn. App. 1026 (1983). We reverse in part and remand for further proceedings. Judith G. Hall, M.D., and Phillip L. Hall, M.D., were married in 1963 while medical school students. In 1966 both received their medical doctorates, served internships and pursued specialized training — Judith in pediatrics and Phillip in cardiology. Returning to Seattle in 1972, Judith was hired by the University of Washington Medical School as an assistant professor. Phillip entered private practice as *238 an internist employed by a private clinic. At the time of trial, Phillip, age 41, enjoyed a good reputation in the community as a consulting cardiologist. In 1975, Phillip and another doctor formed a partnership, which was incorporated in 1977 as Northwest Cardiology Clinic. A third doctor became a shareholder in 1979. Three hospitals, as well as other doctors, referred patients to the clinic which was located on the campus of one of the hospitals. In the 3 years preceding trial, Phillip's average gross yearly earnings, exclusive of retirement contributions, were $52,411.83. Judith, age 40 at the time of trial, was an untenured professor at the University of Washington with no expectation of tenure in the foreseeable future. In the 3 years preceding trial, Judith's average gross yearly earnings, exclusive of employer contributions to her retirement plan, were $32,750. In mid-1980 her salary increased to $42,000. Judith testified that her decision to pursue an academic career was primarily attributable to the need for a flexible schedule in order to care for the Halls' children. Although Judith is widely published and enjoys a reputation as one of the 10 top physicians in the nation in the field of pediatric genetics, there are few, if any, medical career opportunities outside academia, especially in the Seattle area. Numerous medical schools across the nation have offered her employment with salaries up to $60,000. Employment opportunities outside of academia with salaries in the range of $50,000 could be available with some retraining and relocation. The trial court found that Judith had no professional goodwill due to the fact that she was a salaried physician. The court found that Phillip had professional goodwill in the amount of $70,000. A decree of dissolution was entered accordingly. The Court of Appeals affirmed the trial court's holdings; Phillip Hall petitioned for review. Evaluation of professional goodwill is a troublesome issue. Since 1976, professional goodwill has been recognized in Washington as property of an intangible nature subject *239 to division in a marriage dissolution. In re Marriage of Lukens, 16 Wn. App. 481 , 558 P.2d 279 (1976). It is often defined as the "expectation of continued public patronage". Lukens, at 483. Justice Story has more thoroughly defined professional goodwill as: a benefit or advantage "which is acquired by an establishment beyond the mere value of the capital, stock, funds or property employed therein, in consequence of the general public patronage and encouragement, which it receives from constant or habitual customers on account of its local position, or common celebrity, or reputation for skill or affluence, or punctuality, or from other accidental circumstances or necessities, or even from ancient partialities or prejudices." Lukens, at 483-84, citing In re Marriage of Foster, 42 Cal. App. 3d 577 , 117 Cal. Rptr. 49 (1974). In 1979, reviewing the decisions of other courts, this court noted that a number of states had refused, in a divorce proceeding, to assign a value to goodwill of a professional practice, but adopted the Lukens recognition of goodwill as a marital asset. In re Marriage of Fleege, 91 Wn.2d 324 , 588 P.2d 1136 (1979). In Fleege, the issue was whether the goodwill of the husband's solo dental practice was a community asset. Despite expert testimony establishing that the value of his dental practice included goodwill, the trial court had refused to include goodwill as an asset subject to distribution. This court held that, although professional goodwill is not readily salable, the important consideration is not whether the goodwill of the practice could be sold without the personal services of the professional, but whether it has value to him. Fleege, at 327. The dissent contended that goodwill is not a marital asset subject to division because no true goodwill could exist separate and apart from the services of the practitioner. Fleege, at 330-36 (Stafford, J., dissenting). Since Fleege, this court has not ruled further on the concept of goodwill. The Court of Appeals, however, applied the principles of Fleege to a case involving a lawyer in solo practice. In re Marriage of Freedman, 23 Wn. App. 27 , 592 *240 P.2d 1124 (1979) (Freedman I). In Freedman I, the trial court had included the lawyer's goodwill, valued at $100,000, in the community assets to be distributed. While adhering to Fleege, the Court of Appeals nevertheless remanded the case so that further testimony could be taken on all the factors set forth in Fleege. Although the existence of goodwill was not then at issue, the trial court, upon remand, found that goodwill could not exist in a solo law practice because it could not be sold. Instead, the trial court awarded the wife $19,451 as her "spouse's economic benefit expectancy" (SEBE). On a second appeal, the Court of Appeals did not analyze the nature of SEBE, nor did it consider the correctness of the trial court's finding of lack of goodwill. In re Marriage of Freedman, 35 Wn. App. 49, 51 , 665 P.2d 902 (1983) (Freedman II). The Court of Appeals held that regardless of the name given, the trial court had considered the Fleege factors as required in Freedman I. Therefore, the award to the wife as SEBE was affirmed. The last case to discuss professional goodwill was In re Marriage of Kaplan, 23 Wn. App. 503 , 597 P.2d 439 (1979), which involved an attorney who was a "special partner" in a law firm. The trial court found that attorneys in general do not possess goodwill as an item of property. Alternatively, it found that even if attorneys in general do have goodwill, Mr. Kaplan did not. Relying on Freedman I, the Court of Appeals held that the legal question of whether an attorney has goodwill was foreclosed. The Kaplan court reversed and remanded for consideration of those factual elements used in determining the value of goodwill as discussed in Fleege and Freedman I. The husband here contends that the Fleege doctrine should be reconsidered because (1) it presents confusing and unfair criteria for identifying and evaluating the economic benefit to one spouse or the other, from a professional degree and career; and, (2) it is unfair where, as here, it requires the determination that only one of two spouses, with identical professional educations and earning capaci *241 ties, has professional goodwill. These contentions are based on the failure to distinguish between professional goodwill and personal earning capacity of the professional. Goodwill is a property or asset which usually supplements the earning capacity of another asset, a business or a profession. Goodwill is not the earning capacity itself. It is a distinct asset of a professional practice, not just a factor contributing to the value or earning capacity of the practice. Comment, Professional Goodwill in Louisiana: An Analysis of its Classification, Valuation, and Partition, 43 La. L. Rev. 119 , 123 (1982); 38 Am. Jur. 2d Good Will § 8, at 916 (1968). Discontinuance of the business or profession may greatly diminish the value of the goodwill but it does not destroy its existence. When a professional retires or dies, his earning capacity also either retires or dies. Nevertheless, the goodwill that once attached to his practice may continue in existence in the form of established patients or clients, referrals, trade name, location and associations which now attach to former partners or buyers of the practice. Comment, Identifying, Valuing, and Dividing Professional Goodwill as Community Property at Dissolution of the Marital Community, 56 Tul. L. Rev. 313 , 320 (1981). Reference to Judge Reed's example in Lukens, at 485, illustrates the difference in that a professional can transport all of his skill (earning capacity) to a new town, but patients or clients, reputation and referrals (goodwill) cannot always be transported. Once goodwill is distinguished from earning capacity, the error becomes apparent in the argument that a practicing professional and a salaried professional, with equal earning capacities and educations, both have goodwill. Both have earning capacities, and, yet, only the practicing professional has a business or practice to which the goodwill can attach. The practicing professional brings an earning capacity to the practice comprised of skill and education. The goodwill, comprised of such things as location, referrals, associations, reputation, trade name and office organization, can directly supplement this earning capacity. *242 When the practicing professional dies, retires or moves, he takes his skill and education with him, but the goodwill factors must be transferred or otherwise left behind. The goodwill may exist even though it is not marketable. In re Marriage of Freedman, 23 Wn. App. 27 , 592 P.2d 1124 (1979). The salaried professional also brings an earning capacity comprised of skill and education to the position. However, when the salaried professional leaves a position, he takes everything with him to the new position. There is nothing that increased his earning capacity in the old salaried position that cannot be taken to the new position. The Court of Appeals and petitioner's expert witnesses distinguished between goodwill and earning capacity when they recognized that, by definition, a person working solely for a salary as an employee has no goodwill. We adopt the Court of Appeals holding and hold that as a matter of law a salaried employee such as Judith Hall cannot have goodwill. We turn now to the matter of Phillip Hall's goodwill. When the Court of Appeals first recognized that the practice of a professional may include goodwill it looked to the California courts for guidance. The Court of Appeals in In re Marriage of Lukens, 16 Wn. App. 481 , 558 P.2d 279 (1976) and the Supreme Court in In re Marriage of Fleege, 91 Wn.2d 324 , 588 P.2d 1136 (1979) adopted both the holding of In re Marriage of Lopez, 38 Cal. App. 3d 93 , 113 Cal. Rptr. 58 (1974) and the factors set out by that court for valuation of the goodwill. The factors: the practitioner's age, health, past demonstrated earning power, professional reputation in the community as to his judgments, skill, knowledge and his comparative professional success, have become known as the Fleege factors. Two areas surrounding the Fleege factors must be clarified: (1) the first step in evaluation under the Fleege factors is the determination of the existence of goodwill and (2) several accounting or appraisal methods may be used by the trial court in conjunction with the Fleege factors. *243 The Lopez court warned that evaluation of goodwill must be done with considerable care and caution. Lopez, at 110. In carrying out this warning the court instructed that the trial courts should first determine if goodwill exists in a particular practice. Not every professional business as a going concern necessarily has goodwill. Lopez, at 109. The Washington goodwill cases to date have not recognized this preliminary inquiry and we do so today. This preliminary inquiry takes place during the general evaluation process. The trial court must bear in mind throughout this process that there may be zero goodwill. The Fleege factors, under which the determination of existence and evaluation are made, give little guidance to the trial courts. Although we continue to require their usage when appropriate, i.e., when those factors are present, during valuation of goodwill, we now recognize various methods which may be used in conjunction with these factors. The Fleege factors cannot be evaluated and valued in isolation. One or more of the accepted methods of valuation must be employed. The particular method used by the trial court will depend on the offered proof. Because evidence available to the court varies greatly from case to case, selection of any one method for all cases would unnecessarily limit the court in making a fair and just distribution. In valuing goodwill five major formulas have been articulated. See generally Comment, Identifying, Valuing, and Dividing Professional Goodwill as Community Property at Dissolution of the Marital Community, 56 Tul. L. Rev. 313 (1981); Comment, The Recognition and Valuation of Professional Goodwill in the Marital Estate, 66 Marq. L. Rev. 697 (1983); Dlugatch & Olds, Determining Goodwill in a Professional Practice for Purpose of a Community Property Division in a Marital Dissolution, 9 Community Prop. J. 120 (1982). There are three accounting formulas. Under the straight capitalization accounting method the average net profits of the practitioner are determined and this figure is capitalized at a definite rate, as, for example, 20 per *244 cent. This result is considered to be the total value of the business including both tangible and intangible assets. To determine the value of goodwill the book value of the business' assets are subtracted from the total value figure. 1 The second accounting formula is the capitalization of excess earnings method. Under the pure capitalization of excess earnings the average net income is determined. From this figure an annual salary of average employee practitioner with like experience is subtracted. The remaining amount is multiplied by a fixed capitalization rate to determine the goodwill. 2 The IRS variation of capitalized excess earnings method takes the average net income of the business for the last 5 years and subtracts a reasonable rate of return based on the business' average net tangible assets. From this amount a comparable net salary is subtracted. Finally, this remaining amount is capitalized at a definite rate. The resulting amount is goodwill. 3 The fourth method, the market value approach, sets a value on professional goodwill by establishing what fair price would be obtained in the current open market if the practice were to be sold. This method necessitates that a *245 professional practice has been recently sold, is in the process of being sold or is the subject of a recent offer to purchase. Otherwise, the value may be manipulated by the professional spouse. The fifth valuation method, the buy/sell agreement method, values goodwill by reliance on a recent actual sale or an unexercised existing option or contractual formula set forth in a partnership agreement or corporate agreement. Since the professional spouse may have been influenced by many factors other than fair market value in negotiating the terms of the agreement, courts relying on this method should inquire into the presence of such factors, as well as the arm's length nature of the transaction. These five methods are not the exclusive formulas available to trial courts in analyzing the evidence presented. Nor must only one method be used in isolation. One or more methods may be used in conjunction with the Fleege factors to achieve a just and fair evaluation of the existence and value of any professional's goodwill. The danger of using any one method without regard to the Fleege factors is apparent in the present case where petitioner's expert witnesses used only the capitalized excess earnings approach. Under this approach the experts testified that Phillip had no goodwill. Further testimony, however, indicated that Phillip's comparatively low earnings were a result of office expansion expenses, a deliberate decision to limit hours of practice and failure to compare Phillip with cardiologists in the same age and experience group doing similar procedures in Seattle. Consideration of the petitioner's reputation, associations, referrals, location and trade name indicate the existence of goodwill. This case also exemplifies the need for caution in the use of the buy/sell agreement. The Northwest Cardiology Clinic buy/sell agreement does not include a goodwill factor. When the third doctor became a shareholder, no value was assigned to goodwill. The trial court must, however, inquire whether the omission in the agreement was the result of other factors or deliberations on the part of the sharehold *246 ers, particularly when the particular agreement is made in close proximity in time to the divorce. Although an analysis of the evidence suggests the existence of goodwill in Phillip's practice, there is insufficient evidence as to the court's valuation of $70,000. Valuation of goodwill is a question of fact, Suther v. Suther, 28 Wn. App. 838 , 627 P.2d 110 , review denied, 95 Wn.2d 1029 (1981). Findings of fact supported by substantial evidence in the record will not be reversed on appeal. Trans-Canada Enters., Ltd. v. King Cy., 29 Wn. App. 267, 271 , 628 P.2d 493 , review denied, 96 Wn.2d 1002 (1981). Substantial evidence is evidence sufficient to persuade a fair-minded person of the truth of the declared premise. Smith v. Shannon, 100 Wn.2d 26 , 666 P.2d 351 (1983); Ridgeview Properties v. Starbuck, 96 Wn.2d 716 , 638 P.2d 1231 (1982). The trial court found that Phillip had goodwill in the amount of $70,000 "based on the court's evaluation of the factors involved in determining goodwill". The court failed, however, to indicate what factors and method were used in valuation and, in fact, noted in its oral ruling: I am not going to go over all of my reasons. I have simply been persuaded that it exists in the consideration of the status of the practice. Report of Proceedings, at 129. The record with regard to Phillip Hall's goodwill consists of the testimony of petitioner's expert witnesses and Judith Hall, and the accounting records of Phillip's earnings and tangible business assets. Petitioner's experts, an accountant and an economist, testified that based solely on the capitalized excess earnings approach, Phillip has no goodwill. Judith testified that based on other dissolution actions involving physicians, Phillip's goodwill is at least $100,000. Judith's testimony was the only evidence which assigned value to Phillip's goodwill. Her value was not based upon any analysis or upon application of any recognized valuation methodology. Nonetheless, it came in without objection. We, therefore, express no opinion as to its admissibility. *247 The evidence set forth in the record is insufficient to support the finding that Phillip has $70,000 worth of goodwill. The unsubstantiated opinion of Judith and the records of Phillip's earnings and tangible assets are insufficient, without further analysis by the trial court, to persuade a fair-minded person that the $70,000 figure is the true value of Phillip's goodwill. The trial court must set forth on the record which factors and method were used in reaching its finding. We, therefore, reverse and remand for further findings by the trial court in accordance with the valuation guidelines set forth herein. Petitioner also raises the issue of the proper method of analyzing the future earning potential that Judith Hall has gained during marriage. Petitioner contends that the increase in earning potential, as evidenced by Judith's numerous published writings, her excellent reputation in her field and recent job offers, is an asset so similar to goodwill that it should be considered to offset his goodwill. Although treatment of future earning capacity as a distinct marital asset has been advocated, see Comment, A Property Theory of Future Earning Potential in Dissolution Proceedings, 56 Wash. L. Rev. 277 (1981), this court has declined to treat it as such. Recently, we have emphasized future earning capacity as a factor to be considered in property distribution in the context of professional degrees. In re Marriage of Washburn, 101 Wn.2d 168 , 677 P.2d 152 (1984). In Washburn, we discussed a line of cases which view the professional degree (or the enhanced earning potential which it represents) as property, to be valued and distributed upon dissolution of marriage; as nonproperty, but as a factor deserving of a restitutionary award; as non-property to be considered in alimony; and as nonproperty deserving of no compensation. Washburn, at 174-75. As we held in the context of professional degrees, we now hold that the provisions of our dissolution of marriage act, codified in RCW 26.09, provide for a fair and just treatment of future earning potential. RCW 26.09.080 reads in part: *248 In a proceeding for dissolution of the marriage, legal separation, . . . the court shall, without regard to marital misconduct, make such disposition of the property and the liabilities of the parties, either community or separate, as shall appear just and equitable after considering all relevant factors including, but not limited to: (1) The nature and extent of the community property; (2) The nature and extent of the separate property; (3) The duration of the marriage; and (4) The economic circumstances of each spouse at the time the division of property is to become effective, including the desirability of awarding the family home or the right to live therein for reasonable periods to a spouse having custody of any children. In addition to the four subsections in RCW 26.09.080, which include "[t]he economic circumstances of each spouse at the time the division of property is to become effective," the court should also consider the age, health, education and employment history of the parties and their children, and the future earning prospects of all of them in determining a just and equitable division. DeRuwe v. DeRuwe, 72 Wn.2d 404, 408 , 433 P.2d 209 (1967); In re Marriage of Rink, 18 Wn. App. 549, 551 , 571 P.2d 210 (1977). In Wash-burn we also emphasized the importance of the future earning potential of each spouse by setting it out as one of four factors to be considered in determining the proper amount of compensation for the supporting spouse. Once again we emphasize the importance of consideration of future earning potential. We decline to find that future earning potential is an asset which can be used to offset goodwill. Instead, we hold that it is a substantial factor to be considered by the trial court in making a just and equitable property distribution. On remand, the trial court should articulate its reasoning in taking into account this substantial factor. Williams, C.J., Utter, Dolliver, Dore, Dimmick, and Pearson, JJ., and Cunningham, J. Pro Tern., concur. 1 Average net earnings $60,000 Capitalize at 20% x 5 Total business tangible and intangible assets 300,000 Less current net tangible assets -30,000 Goodwill $270,000 2 Average net earnings $60,000 Less comparable net salary —40,000 Average earnings on intangible assets 20,000 Capitalize at 20% x 5 Goodwill $109,000 3 Average net earnings $60,000 Less rate of return on average tangible assets -2,500 Subtotal $57,500 Less comparable net salary -40,000 Average earnings on intangible assets 17,500 Capitalize at 20% x 5 GoodwiU $87,500 Case-law data current through December 31, 2025. Source: CourtListener bulk data . 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Hall Approved +Free Access to American Case Law
Washington Supreme Court, 1985 +

In Re the Marriage of Konzen

In Re the Marriage of Konzen
Washington Supreme Court · Decided January 11, 1985 · Dimmick, Brachtenbach
693 P.2d 97; 103 Wash. 2d 470; 1985 Wash. LEXIS 1058 +(Pacific Reporter, Second Series)

In Re the Marriage of Konzen

Opinion of the Court

Dimmick, J.

This appeal challenges the trial court's award of a portion of petitioner's military retired pay to his former spouse where that military retired pay accrued prior to their marriage and was his separate property. We hold that the trial court had the authority to make such an award and did not abuse its discretion in so doing.

Prior to Joseph and Geraldine Konzens' marriage on June 22, 1970, Mr. Konzen had retired from a 25-year career with the United States Navy. This was a second marriage for each party. At the time of trial, he was receiving $1,653 per month in military retired pay. Although both parties were unemployed at the time of trial, the trial court found that Mr. Konzen had a substantially and disproportionately greater earning capacity than Mrs. Konzen. Mr. Konzen holds an undergraduate degree and a master's degree. Until just prior to trial, he had worked as a manager for the Kitsap Golf and Country Club. Mrs. Konzen has not completed high school. She has worked occasionally as a waitress and a retail clerk. Both parties have health problems. Mr. Konzen suffers from a vascular problem which causes his right leg to bleed after prolonged sitting or standing. Mrs. Konzen is a recovering alcoholic.

A final decree of dissolution was entered on September 26, 1980. The trial court characterized Mr. Konzen's military retired pay as his separate property. The rest of the parties' property was characterized as community property. The trial court apportioned the Konzens' community property approximately equally. In addition, it awarded 30 percent of Mr. Konzen's military retired pay to Mrs. Konzen. The trial court based the property division on the economic circumstances of the parties. In its oral opinion, it stated that it had chosen to award a portion of Mr. Konzen's separate property, rather than a disproportionate share of the community property, to Mrs. Konzen because the military retired pay was a more liquid asset.

*473Mr. Konzen appealed the award of 30 percent of his military retired pay. The Court of Appeals modified the award to cut off Mrs. Konzen's interest at her death, but otherwise affirmed the property division made by the trial court.

Petitioner herein contends that the trial court lacked subject matter jurisdiction over his military retired pay. We disagree. The trial court acted within its authority when it awarded a portion of the petitioner's military retired pay to his former wife. Wilder v. Wilder, 85 Wn.2d 364, 366-67, 534 P.2d 1355 (1975). While the Konzens' appeal was pending, the United States Supreme Court held in McCarty v. McCarty, 453 U.S. 210, 69 L. Ed. 2d 589, 101 S. Ct. 2728 (1981) that state courts could not divide military retired pay as part of a property division in a dissolution. However, nothing in McCarty indicates that it was intended to divest the state courts of jurisdiction over military retired pay. McCarty merely changed the rule of law to prohibit the division of military retired pay as community or marital property. In re Marriage of Brown, 98 Wn.2d 46, 49, 653 P.2d 602 (1982); In re Marriage of Smith, 98 Wn.2d 772, 774, 657 P.2d 1383 (1983). Accord, In re Marriage of De Gryse, 135 Ariz. 335, 338, 661 P.2d 185, 188 (1983).

Even under McCarty, the trial court would have had jurisdiction over Mr. Konzen's military retired pay as his separate property. RCW 26.09.080. In fact, the United States Supreme Court indicated that a state would be allowed to order the payment of spousal support or child support out of military retired pay. McCarty, at 230. In addition, a state court continued to be able to consider the effect of military retired pay on the economic circumstances of the parties when making an equitable division of their property. In re Marriage of Dessauer, 97 Wn.2d 831, 839, 650 P.2d 1099 (1982). The trial court had subject matter jurisdiction over Mr. Konzen's military retired pay and later changes in federal law did not affect that jurisdiction.

The Uniformed Services Former Spouses' Protection Act (USFSPA) now allows state law to control the division of military retired pay as part of a property settlement in a *474dissolution. 10 U.S.C. § 1408(c) (1982). Congress intended that the USFSPA apply retroactively to eliminate all effects of the McCarty decision. 10 U.S.C. § 1408(c)(1); S. Rep. No. 502, 97th Cong., 2d Sess. 15, reprinted in 1982 U.S. Code Cong. & Ad. News 1596, 1611. In keeping with this intent, we review the award of Mr. Konzen's military retired pay in light of the requirements of the act. In re Marriage of Smith, 100 Wn.2d 319, 669 P.2d 448 (1983).

Petitioner next argues that the award was improper under the USFSPA. He interprets the USFSPA to allow state courts to award a portion of military retired pay as part of a property division only if the parties' marriage has lasted for more than 10 years during the service member's military career. In dicta, this court has referred to such a limitation in the USFSPA. In re Marriage of Smith, at 323. See also In re Marriage of Wood, 34 Wn. App. 892, 893, 664 P.2d 1297 (1983).

However, this issue is raised directly for the first time in this case. In In re Marriage of Smith, the parties had been married for almost 20 years, most of which were during the husband's military career. The Konzens were married for slightly more than 10 years, but were not married during any part of Mr. Konzen's service in the Navy.

Petitioner relies on language in section 1408(d)(2) of the USFSPA which states:

If the spouse or former spouse to whom payments are to be made under this section was not married to the member for a period of 10 years or more during which the member performed at least 10 years of service creditable in determining the member's eligibility for retired or retainer pay, payments may not be made under this section to the extent that they include an amount resulting from the treatment by the court under subsection (c) of disposable retired or retainer pay of the member as property of the member or property of the member and his spouse.

However, it is not clear from the structure of the statute whether this 10-year requirement applies to every division of property authorized under section 1408(c) or only to *475direct payments by the government to a former spouse authorized under section 1408(d). When the language of a statute is ambiguous, this court will look to the legislative history to determine Congress' intent. Bellevue Fire Fighters Local 1604 v. Bellevue, 100 Wn.2d 748, 675 P.2d 592 (1984).

The legislative history clearly indicates that Congress did not intend to limit the application of the USFSPA to marriages lasting over 10 years during the service member's military career.

The Department of Defense had urged the Senate to adopt such a 15-year requirement, but this recommendation was rejected in committee. S. Rep. No. 502, 97th Cong., 2d Sess. 9-10, reprinted in 1982 U.S. Code Cong. & Ad. News 1596, 1604-05. The USFSPA as originally passed by the House had been amended to limit its application to marriages lasting more than 10 years. 128 Cong. Rec. H4726, H4736 (daily ed. July 28, 1982) (Nichols amendment). Section 1408(c)(1) of the original House version stated:

Subject to the limitations of this section, a court may treat disposable retired or retainer pay payable to a member for pay periods beginning on or after June 26, 1981, either as property solely of the member or as property of the member and his spouse in accordance with the law of the jurisdiction of such court if the spouse was married to the member for a period of not less than 10 years during which the member performed at least 10 years of service which is creditable in determining the member's eligibility for retired or retainer pay, or equivalent pay, as a result of his service in any of the uniformed services.

128 Cong. Rec. H4726. The language in section 1408(c) limiting the application of the USFSPA to marriages lasting more than 10 years during the service member's military career was deleted in the conference committee. H. Rep. No. 749, 97th Cong., 2d Sess. 166-67, reprinted in 1982 U.S. Code Cong. & Ad. News 1570, 1572. The conference report states:

*476The conferees agreed to remove the restriction that would require 10 years of marriage before military retired pay could be considered property by the courts. The conferees further agreed, however, that direct payments by the service finance centers to a former spouse from the member's retired pay based on a division of that retired pay as property would be limited to situations in which the former spouse was married to the member for at least 10 years while the member performed military service. The 10-year restriction would not apply to direct payments based on the award of child support or alimony.
Currently, there is no Federal enforcement mechanism for court-ordered property division of military retired pay available to former spouses of military personnel. The conferees agreed to a Federal enforcement provision as described above; however, jurisdiction of the courts to consider military retired pay when fixing the property rights between the parties to a divorce, dissolution, legal separation or annulment would not be affected by the 10-year marriage requirement.

As passed, section 1408(c)(1) of the USFSPA states:

Subject to the limitations of this section, a court may treat disposable retired or retainer pay payable to a member for pay periods beginning after June 25, 1981, either as property solely of the member or as property of the member and his spouse in accordance with the law of the jurisdiction of such court.

This interpretation of the USFSPA is in accord with rulings in other jurisdictions. A number of courts have made reference to a 10-year requirement in the USFSPA. However, in each of these cases the marriage under consideration had lasted for more than 10 years during the service member's military career and the issue was not squarely before the courts. In re Marriage of Smith, at 320; Coates v. Coates, 650 S.W.2d 307, 311 (Mo. Ct. App. 1983); In re Marriage of Costo,_Cal. App. 3d_, 203 Cal. Rptr. 85, 89 (1984). Every court which has directly considered this issue has determined that a state court's authority to divide military retired pay is not limited to cases in which the marriage has lasted for more than 10 years during the serv*477ice member's military career. In re Marriage of Wood, 66 Or. App. 941, 944-46, 676 P.2d 338 (1984); Oxelgren v. Oxelgren, 670 S.W.2d 411, 412 (Tex. Ct. App. 1984). See also Horkovich, Uniformed Services Former Spouses' Protection Act: Congress' Answer to McCarty v. McCarty Goes Beyond the Fundamental Question, 23 A.F. 287, 307 (1982-83). We likewise so hold.

The final issue raised by petitioner is whether the trial court abused its discretion in awarding a portion of petitioner's separate property, 30 percent of his military retired pay, to his former spouse. Petitioner relies on Bodine v. Bodine, 34 Wn.2d 33, 35, 207 P.2d 1213 (1949), in which the court stated that the situations which warrant an award of one spouse's separate property to the other spouse are "exceptional." At the time Bodine was decided the statute governing the division of property in a divorce stated:

In granting a divorce, the court shall also make such disposition of the property of the parties as shall appear just and equitable, having regard to the respective merits of the parties, and to the conditions in which they will be left by such divorce, and to the party through whom the property was acquired, and to the burdens imposed upon it for the benefit of the children, and shall make provision for the guardianship, custody, and support and education of the minor children of such marriage.

Rem. Rev. Stat. § 989. While both separate and community property have always been considered to be before the court in a dissolution action, it was not until the statute was revised in 1949 that the allocation of separate property was explicitly governed by statutory criteria. Laws of 1949, ch. 215, § 11, p. 701. Prior to this change the courts were free to weigh the character of the property more heavily than other factors when allocating separate property.

However the current statute specifically applies the statutory criteria to separate property. RCW 26.09.080 states:

In a proceeding for dissolution of the marriage . . . the court shall, without regard to marital misconduct, make such disposition of the property and the liabilities of the *478parties, either community or separate, as shall appear just and equitable after considering all relevant factors including, but not limited to:

(1) The nature and extent of the community property;

(2) The nature and extent of the separate property;

(3) The duration of the marriage; and

(4) The economic circumstances of each spouse at the time the division of property is to become effective, including the desirability of awarding the family home or the right to live therein for reasonable periods to a spouse having custody of any children.

(Italics ours.) This court will not single out a particular factor, such as the character of the property, and require as a matter of law that it be given greater weight than other relevant factors. The statute directs the trial court to weigh all of the factors, within the context of the particular circumstances of the parties, to come to a fair, just and equitable division of property. The character of the property is a relevant factor which must be considered, but is not controlling. In re Marriage of Hadley, 88 Wn.2d 649, 656, 565 P.2d 790 (1977). The decision of the trial court will not be disturbed on appeal absent a manifest abuse of discretion. In re Marriage of Miracle, 101 Wn.2d 137, 139, 675 P.2d 1229 (1984). Under the circumstances of this case, we find no abuse of discretion.

Respondent's request for attorney's fees is denied. RCW 26.09.140 allows a court to award attorney's fees if a party demonstrates financial need. Respondent has made no present showing of financial need, and petitioner's claim was not frivolous. We affirm the trial court award as modified by the Court of Appeals.

Williams, C.J., and Utter, Dore, Pearson, and Andersen, JJ., concur.

Dissenting Opinion

Brachtenbach, J.

(dissenting) — The majority holds that a state court's authority to divide military retired pay is not limited to cases in which the marriage has lasted for more than 10 years during the service member's military career. Although policy considerations may favor this holding, it *479requires an interpretation of the applicable statute which totally disregards the rules of statutory construction established by this court. Discretionary application of the rules of statutory construction destroys their value and leads to unnecessary judicial tampering. For this reason I dissent.

Petitioner contends that the award of his military retired pay was improper under the Uniformed Services Former Spouses' Protection Act (USFSPA). He interprets the USFSPA to allow state courts to award a portion of military retired pay as part of a property division only if the parties' marriage has lasted for more than 10 years during the service member's military career.

Petitioner relies on language in 10 U.S.C. § 1408(d)(2) of the USFSPA which provides:

If the spouse or former spouse to whom payments are to be made under this section was not married to the member for a period of 10 years or more during which the member performed at least 10 years of service creditable in determining the member's eligibility for retired or retainer pay, payments may not be made under this section to the extent that they include an amount resulting from the treatment by the court under subsection (c) of disposable retired or retainer pay of the member as property of the member or property of the member and his spouse.

(Italics mine.) Petitioner contends that the 10-year requirement of subsection (d)(2) is made applicable to the entire section 1408 by the language "under this section". Therefore, he argues no division is proper under section 1408 unless the couple was married during at least 10 years of service.

The majority summarily concludes that an ambiguity exists as to whether section 1408(d)(2) applies to subsection (d) alone or to the entire section 1408. In this way the majority introduces the legislative history which becomes the basis for its analysis. The majority does not identify or discuss the ambiguity in subsection (d). Indeed, it cannot, because no ambiguity exists.

The intent of the Legislature must be determined pri*480marily from the language of the statute itself, and where the language is plain and free from ambiguity, there is no room for construction, because the meaning will be discovered from the wording of the statute itself. Ford Motor Credit Co. v. Cenance, 452 U.S. 155, 68 L. Ed. 2d 744, 101 S. Ct. 2239 (1981), on remand sub nom. Cenance v. Bohn Ford, Inc., 666 F.2d 97 (5th Cir. 1982); People's Org. for Wash. Energy Resources v. Utilities & Transp. Comm'n, 101 Wn.2d 425, 679 P.2d 922 (1984); Bellevue Fire Fighters Local 1604 v. Bellevue, 100 Wn.2d 748, 675 P.2d 592 (1984). Accordingly, when a term used in a statute is not defined therein, it should be given its ordinary meaning. State ex rel. Graham v. Northshore Sch. Dist. 417, 99 Wn.2d 232, 662 P.2d 38 (1983). This is so even if the court, as draftsman, might have used or preferred a different choice of language than that employed by the Legislature. Guinness v. State, 40 Wn.2d 677, 246 P.2d 433 (1952).

In the present case, the language of subsection (d), paragraph (2) is plain and free from ambiguity. The 10-year requirement set forth here is clearly made applicable to the entire section 1408 by the language "under this section". The majority's assertion that it could apply either to the entire section 1408 or only to subsection (d) is simply not supportable under this language. "Section" is defined as a distinct part or portion of a writing as a subdivision of a chapter. Webster's Third New International Dictionary 2052 (1961). Section 1408 is within chapter 71 and is a subdivision of this chapter. Subsection (d) is a further division of section 1408; subsection (d) is not properly termed a " section".

An examination of the statute itself is conclusive proof that the word "section" encompasses every part of section 1408(a) through (h). The introductory language states:

Sec. 1002. (a) Chapter 71 of title 10, United States Code, is amended by adding at the end thereof the following new section:

96 Stat. 730, Pub. L. No. 97-252 (1982). Thereafter there follows in quotation marks all of section 1408(a) through *481(h). In other words, the introductory language itself defines "section" by stating that there is added a new section. What is contained within that section is indicated by the quotation marks in front of "§ 1408" through the last word in (h). The entire section 1408 is the new section. Because the phrase "under this section" can only apply to the entire section 1408, no ambiguity exists and therefore statutory construction is improper.

The Legislature's use of the words "section" and "subsection" in the entirety of section 1408 supports the contention that the 10-year requirement of subsection (d)(2) applies to the entire section 1408. When construing a statute, courts must read the act as a whole and not piecemeal. State v. Parker, 97 Wn.2d 737, 649 P.2d 637 (1982); Burlington N., Inc. v. Johnston, 89 Wn.2d 321, 572 P.2d 1085 (1977). Throughout section 1408 the Legislature used the term "section" to refer to the entire act. For example, the codification index of chapter 71 of Title 10 lists the sections of the chapter. Section 1408 is listed under the heading "sections". We can therefore presume it knew to what that term correctly referred.

In addition, specific subsections are referred to. In section 1408(b)(1)(A) and in section 1408(f)(1) and (2) the term "subsection" is used to refer to subsection (h). In section 1408(d)(2) itself subsection (c) is referred to. In section 1408(d)(5) the division of paragraph is referred to, supporting further distinction between sections, subsections, and paragraphs. And most importantly, the subsection in question, subsection (d), is correctly referred to as "subsection" in section 1408(e)(1). It is obvious that the Legislature knew the difference between "section" and "subsection" and had it wanted to limit the 10-year requirement to subsection (d) it would have used the proper term.

If the majority is correct in its conclusion that the limitation in section 1408(d)(2) is limited only to direct payments made under section 1408(d)(1), then the whole act is rendered a shambles. For example, section 1408(a)(1) *482through (6) provides the definitions of the words "court", "court order", "final decree", "disposable retired or retainer pay", "member" and "spouse or former spouse". Under the majority's analysis these terms would apply only to section 1408(a). Thus, the definitions therein provided would stand alone and section 1408(a) would be meaningless. Likewise, section 1408(b) which determines when service of a court order is effective and when it is regular on its face would apply only to itself and would stand as a meaningless collection of words, applicable to nothing.

In addition, section 1408(h) is utterly meaningless under the majority's analysis. In its entirety it provides: "[t]he Secretaries concerned shall prescribe uniform regulations for the administration of this section." The majority's holding would limit such regulations to the administration of section 1408(h) which only authorizes the issuances of regulations.

Obviously, each subsection cannot refer solely to itself. The language "under this section" must refer to the entire section 1408 or the act is rendered useless. For example, the trial court disposed of the military pension by court order. The court order must fulfill the requirements of subsection (a)(2) before the military retired payments may be divided. The court order in this case is the very type of order section 1408 is designed to deal with. Then subsection (c) comes into play by announcing that such division is possible. And finally subsection (d) limits the division in various ways. The subsections are meant to work together and each is designed to apply to the entire section 1408.

It may well be that the conference report, cited by the majority, is what the members of the conference committee intended. However, that is not what the drafter of the bill itself put into the document ultimately passed.

The interpretation which applies the 10-year requirement of subsection (d)(2) to the entire statute is reconcilable with the intent apparent in the remainder of the statute. The idea that the Legislature wanted to limit state courts' authority to divide military retired pay to cases *483where the marriages lasted a reasonable period of time fits into the general scheme of offering some protection to the retiring spouse. Section 1408(c)(3) similarly protects this spouse by not giving courts the authority to order the service member spouse to retire or apply for retirement so as to effectuate payment under section 1408. Subsection (d) provides for various limitations which protect the retiring spouse to an extent. Subsection (d), paragraph (1) requires a court order before benefits can be paid directly to the spouse or former spouse. Subsection (d), paragraph (3) provides that a court may not order payments to be made more often than cice each month. Any payment, direct or other, would occur most beneficially for both spouses at a time when money was available, after the government's monthly payment. Subsection (d), paragraph (4) limits payment under section 1408 to the time when the retired or retiring spouse is still alive. Subsection (d), paragraph (5) sets forth the procedure for garnishment of the military retired pay. Each of these paragraphs of subsection (d) refer to the "section" and each is reconcilable to the interpretation that they limit the entire section 1408. Contrary to the holding in In re Marriage of Wood, 66 Or. App. 941, 676 P.2d 338 (1984), the limitation in (d)(1), requiring a court order before benefits are paid directly to the spouse or former spouse, is not necessarily applicable to the entire subsection (d). Each of the paragraphs are separate limitations on section 1408.

Because there is no ambiguity in subsection (d) and the ordinary meaning applied to the questioned term is reconcilable with the remainder of the statute, I would hold that the 10-year requirement of subsection (d)(2) applies to the entire act. Therefore, I would reverse and remand.

Dolliver, J., concurs with Brachtenbach, J.

Reconsideration denied February 15, 1985.

Case-law data current through December 31, 2025. Source: CourtListener bulk data.

↑ + \ No newline at end of file diff --git a/.research/konzen.txt b/.research/konzen.txt new file mode 100644 index 0000000..23c3d9b --- /dev/null +++ b/.research/konzen.txt @@ -0,0 +1 @@ +In Re the Marriage of Konzen, 693 P.2d 97 (Wash. 1985) | HallApproved.com Hall Approved Free Access to American Case Law Statutes Free Legal Archive / Washington / Cases / Washington Supreme Court / 1985 / Washington Supreme Court, 1985 Copy citation Free Legal Archive / Washington / Cases / Washington Supreme Court / 1985 / In Re the Marriage of Konzen In Re the Marriage of Konzen Washington Supreme Court · Decided January 11, 1985 · Dimmick, Brachtenbach 693 P.2d 97; 103 Wash. 2d 470; 1985 Wash. LEXIS 1058 (Pacific Reporter, Second Series) In Re the Marriage of Konzen Opinions Opinion of the Court Dissenting Opinion Opinion of the Court Dimmick, J. This appeal challenges the trial court's award of a portion of petitioner's military retired pay to his former spouse where that military retired pay accrued prior to their marriage and was his separate property. We hold that the trial court had the authority to make such an award and did not abuse its discretion in so doing. Prior to Joseph and Geraldine Konzens' marriage on June 22, 1970, Mr. Konzen had retired from a 25-year career with the United States Navy. This was a second marriage for each party. At the time of trial, he was receiving $1,653 per month in military retired pay. Although both parties were unemployed at the time of trial, the trial court found that Mr. Konzen had a substantially and disproportionately greater earning capacity than Mrs. Konzen. Mr. Konzen holds an undergraduate degree and a master's degree. Until just prior to trial, he had worked as a manager for the Kitsap Golf and Country Club. Mrs. Konzen has not completed high school. She has worked occasionally as a waitress and a retail clerk. Both parties have health problems. Mr. Konzen suffers from a vascular problem which causes his right leg to bleed after prolonged sitting or standing. Mrs. Konzen is a recovering alcoholic. A final decree of dissolution was entered on September 26, 1980. The trial court characterized Mr. Konzen's military retired pay as his separate property. The rest of the parties' property was characterized as community property. The trial court apportioned the Konzens' community property approximately equally. In addition, it awarded 30 percent of Mr. Konzen's military retired pay to Mrs. Konzen. The trial court based the property division on the economic circumstances of the parties. In its oral opinion, it stated that it had chosen to award a portion of Mr. Konzen's separate property, rather than a disproportionate share of the community property, to Mrs. Konzen because the military retired pay was a more liquid asset. *473 Mr. Konzen appealed the award of 30 percent of his military retired pay. The Court of Appeals modified the award to cut off Mrs. Konzen's interest at her death, but otherwise affirmed the property division made by the trial court. Petitioner herein contends that the trial court lacked subject matter jurisdiction over his military retired pay. We disagree. The trial court acted within its authority when it awarded a portion of the petitioner's military retired pay to his former wife. Wilder v. Wilder, 85 Wn.2d 364, 366-67 , 534 P.2d 1355 (1975). While the Konzens' appeal was pending, the United States Supreme Court held in McCarty v. McCarty, 453 U.S. 210 , 69 L. Ed. 2d 589 , 101 S. Ct. 2728 (1981) that state courts could not divide military retired pay as part of a property division in a dissolution. However, nothing in McCarty indicates that it was intended to divest the state courts of jurisdiction over military retired pay. McCarty merely changed the rule of law to prohibit the division of military retired pay as community or marital property. In re Marriage of Brown, 98 Wn.2d 46, 49 , 653 P.2d 602 (1982); In re Marriage of Smith, 98 Wn.2d 772, 774 , 657 P.2d 1383 (1983). Accord, In re Marriage of De Gryse, 135 Ariz. 335, 338 , 661 P.2d 185, 188 (1983). Even under McCarty , the trial court would have had jurisdiction over Mr. Konzen's military retired pay as his separate property. RCW 26.09.080. In fact, the United States Supreme Court indicated that a state would be allowed to order the payment of spousal support or child support out of military retired pay. McCarty , at 230. In addition, a state court continued to be able to consider the effect of military retired pay on the economic circumstances of the parties when making an equitable division of their property. In re Marriage of Dessauer, 97 Wn.2d 831, 839 , 650 P.2d 1099 (1982). The trial court had subject matter jurisdiction over Mr. Konzen's military retired pay and later changes in federal law did not affect that jurisdiction. The Uniformed Services Former Spouses' Protection Act (USFSPA) now allows state law to control the division of military retired pay as part of a property settlement in a *474 dissolution. 10 U.S.C. § 1408 (c) (1982). Congress intended that the USFSPA apply retroactively to eliminate all effects of the McCarty decision. 10 U.S.C. § 1408 (c)(1); S. Rep. No. 502, 97th Cong., 2d Sess. 15, reprinted in 1982 U.S. Code Cong. & Ad. News 1596, 1611. In keeping with this intent, we review the award of Mr. Konzen's military retired pay in light of the requirements of the act. In re Marriage of Smith, 100 Wn.2d 319 , 669 P.2d 448 (1983). Petitioner next argues that the award was improper under the USFSPA. He interprets the USFSPA to allow state courts to award a portion of military retired pay as part of a property division only if the parties' marriage has lasted for more than 10 years during the service member's military career. In dicta, this court has referred to such a limitation in the USFSPA. In re Marriage of Smith, at 323. See also In re Marriage of Wood, 34 Wn. App. 892, 893 , 664 P.2d 1297 (1983). However, this issue is raised directly for the first time in this case. In In re Marriage of Smith, the parties had been married for almost 20 years, most of which were during the husband's military career. The Konzens were married for slightly more than 10 years, but were not married during any part of Mr. Konzen's service in the Navy. Petitioner relies on language in section 1408(d)(2) of the USFSPA which states: If the spouse or former spouse to whom payments are to be made under this section was not married to the member for a period of 10 years or more during which the member performed at least 10 years of service creditable in determining the member's eligibility for retired or retainer pay, payments may not be made under this section to the extent that they include an amount resulting from the treatment by the court under subsection (c) of disposable retired or retainer pay of the member as property of the member or property of the member and his spouse. However, it is not clear from the structure of the statute whether this 10-year requirement applies to every division of property authorized under section 1408(c) or only to *475 direct payments by the government to a former spouse authorized under section 1408(d). When the language of a statute is ambiguous, this court will look to the legislative history to determine Congress' intent. Bellevue Fire Fighters Local 1604 v. Bellevue, 100 Wn.2d 748 , 675 P.2d 592 (1984). The legislative history clearly indicates that Congress did not intend to limit the application of the USFSPA to marriages lasting over 10 years during the service member's military career. The Department of Defense had urged the Senate to adopt such a 15-year requirement, but this recommendation was rejected in committee. S. Rep. No. 502, 97th Cong., 2d Sess. 9-10, reprinted in 1982 U.S. Code Cong. & Ad. News 1596, 1604-05. The USFSPA as originally passed by the House had been amended to limit its application to marriages lasting more than 10 years. 128 Cong. Rec. H4726, H4736 (daily ed. July 28, 1982) (Nichols amendment). Section 1408(c)(1) of the original House version stated: Subject to the limitations of this section, a court may treat disposable retired or retainer pay payable to a member for pay periods beginning on or after June 26, 1981, either as property solely of the member or as property of the member and his spouse in accordance with the law of the jurisdiction of such court if the spouse was married to the member for a period of not less than 10 years during which the member performed at least 10 years of service which is creditable in determining the member's eligibility for retired or retainer pay, or equivalent pay, as a result of his service in any of the uniformed services. 128 Cong. Rec. H4726. The language in section 1408(c) limiting the application of the USFSPA to marriages lasting more than 10 years during the service member's military career was deleted in the conference committee. H. Rep. No. 749, 97th Cong., 2d Sess. 166-67, reprinted in 1982 U.S. Code Cong. & Ad. News 1570, 1572. The conference report states: *476 The conferees agreed to remove the restriction that would require 10 years of marriage before military retired pay could be considered property by the courts. The conferees further agreed, however, that direct payments by the service finance centers to a former spouse from the member's retired pay based on a division of that retired pay as property would be limited to situations in which the former spouse was married to the member for at least 10 years while the member performed military service. The 10-year restriction would not apply to direct payments based on the award of child support or alimony. Currently, there is no Federal enforcement mechanism for court-ordered property division of military retired pay available to former spouses of military personnel. The conferees agreed to a Federal enforcement provision as described above; however, jurisdiction of the courts to consider military retired pay when fixing the property rights between the parties to a divorce, dissolution, legal separation or annulment would not be affected by the 10-year marriage requirement. As passed, section 1408(c)(1) of the USFSPA states: Subject to the limitations of this section, a court may treat disposable retired or retainer pay payable to a member for pay periods beginning after June 25, 1981, either as property solely of the member or as property of the member and his spouse in accordance with the law of the jurisdiction of such court. This interpretation of the USFSPA is in accord with rulings in other jurisdictions. A number of courts have made reference to a 10-year requirement in the USFSPA. However, in each of these cases the marriage under consideration had lasted for more than 10 years during the service member's military career and the issue was not squarely before the courts. In re Marriage of Smith, at 320; Coates v. Coates, 650 S.W.2d 307, 311 (Mo. Ct. App. 1983); In re Marriage of Costo,_Cal. App. 3d_, 203 Cal. Rptr. 85, 89 (1984). Every court which has directly considered this issue has determined that a state court's authority to divide military retired pay is not limited to cases in which the marriage has lasted for more than 10 years during the serv *477 ice member's military career. In re Marriage of Wood, 66 Or. App. 941, 944-46 , 676 P.2d 338 (1984); Oxelgren v. Oxelgren, 670 S.W.2d 411, 412 (Tex. Ct. App. 1984). See also Horkovich, Uniformed Services Former Spouses' Protection Act: Congress' Answer to McCarty v. McCarty Goes Beyond the Fundamental Question, 23 A.F. 287, 307 (1982-83). We likewise so hold. The final issue raised by petitioner is whether the trial court abused its discretion in awarding a portion of petitioner's separate property, 30 percent of his military retired pay, to his former spouse. Petitioner relies on Bodine v. Bodine, 34 Wn.2d 33, 35 , 207 P.2d 1213 (1949), in which the court stated that the situations which warrant an award of one spouse's separate property to the other spouse are "exceptional." At the time Bodine was decided the statute governing the division of property in a divorce stated: In granting a divorce, the court shall also make such disposition of the property of the parties as shall appear just and equitable, having regard to the respective merits of the parties, and to the conditions in which they will be left by such divorce, and to the party through whom the property was acquired, and to the burdens imposed upon it for the benefit of the children, and shall make provision for the guardianship, custody, and support and education of the minor children of such marriage. Rem. Rev. Stat. § 989. While both separate and community property have always been considered to be before the court in a dissolution action, it was not until the statute was revised in 1949 that the allocation of separate property was explicitly governed by statutory criteria. Laws of 1949, ch. 215, § 11, p. 701. Prior to this change the courts were free to weigh the character of the property more heavily than other factors when allocating separate property. However the current statute specifically applies the statutory criteria to separate property. RCW 26.09.080 states: In a proceeding for dissolution of the marriage . . . the court shall, without regard to marital misconduct, make such disposition of the property and the liabilities of the *478 parties, either community or separate, as shall appear just and equitable after considering all relevant factors including, but not limited to: (1) The nature and extent of the community property; (2) The nature and extent of the separate property; (3) The duration of the marriage; and (4) The economic circumstances of each spouse at the time the division of property is to become effective, including the desirability of awarding the family home or the right to live therein for reasonable periods to a spouse having custody of any children. (Italics ours.) This court will not single out a particular factor, such as the character of the property, and require as a matter of law that it be given greater weight than other relevant factors. The statute directs the trial court to weigh all of the factors, within the context of the particular circumstances of the parties, to come to a fair, just and equitable division of property. The character of the property is a relevant factor which must be considered, but is not controlling. In re Marriage of Hadley, 88 Wn.2d 649, 656 , 565 P.2d 790 (1977). The decision of the trial court will not be disturbed on appeal absent a manifest abuse of discretion. In re Marriage of Miracle, 101 Wn.2d 137, 139 , 675 P.2d 1229 (1984). Under the circumstances of this case, we find no abuse of discretion. Respondent's request for attorney's fees is denied. RCW 26.09.140 allows a court to award attorney's fees if a party demonstrates financial need. Respondent has made no present showing of financial need, and petitioner's claim was not frivolous. We affirm the trial court award as modified by the Court of Appeals. Williams, C.J., and Utter, Dore, Pearson, and Andersen, JJ., concur. Dissenting Opinion Brachtenbach, J. (dissenting) — The majority holds that a state court's authority to divide military retired pay is not limited to cases in which the marriage has lasted for more than 10 years during the service member's military career. Although policy considerations may favor this holding, it *479 requires an interpretation of the applicable statute which totally disregards the rules of statutory construction established by this court. Discretionary application of the rules of statutory construction destroys their value and leads to unnecessary judicial tampering. For this reason I dissent. Petitioner contends that the award of his military retired pay was improper under the Uniformed Services Former Spouses' Protection Act (USFSPA). He interprets the USFSPA to allow state courts to award a portion of military retired pay as part of a property division only if the parties' marriage has lasted for more than 10 years during the service member's military career. Petitioner relies on language in 10 U.S.C. § 1408 (d)(2) of the USFSPA which provides: If the spouse or former spouse to whom payments are to be made under this section was not married to the member for a period of 10 years or more during which the member performed at least 10 years of service creditable in determining the member's eligibility for retired or retainer pay, payments may not be made under this section to the extent that they include an amount resulting from the treatment by the court under subsection (c) of disposable retired or retainer pay of the member as property of the member or property of the member and his spouse. (Italics mine.) Petitioner contends that the 10-year requirement of subsection (d)(2) is made applicable to the entire section 1408 by the language "under this section". Therefore, he argues no division is proper under section 1408 unless the couple was married during at least 10 years of service. The majority summarily concludes that an ambiguity exists as to whether section 1408(d)(2) applies to subsection (d) alone or to the entire section 1408. In this way the majority introduces the legislative history which becomes the basis for its analysis. The majority does not identify or discuss the ambiguity in subsection (d). Indeed, it cannot, because no ambiguity exists. The intent of the Legislature must be determined pri *480 marily from the language of the statute itself, and where the language is plain and free from ambiguity, there is no room for construction, because the meaning will be discovered from the wording of the statute itself. Ford Motor Credit Co. v. Cenance, 452 U.S. 155 , 68 L. Ed. 2d 744 , 101 S. Ct. 2239 (1981), on remand sub nom. Cenance v. Bohn Ford, Inc., 666 F.2d 97 (5th Cir. 1982); People's Org. for Wash. Energy Resources v. Utilities & Transp. Comm'n, 101 Wn.2d 425 , 679 P.2d 922 (1984); Bellevue Fire Fighters Local 1604 v. Bellevue, 100 Wn.2d 748 , 675 P.2d 592 (1984). Accordingly, when a term used in a statute is not defined therein, it should be given its ordinary meaning. State ex rel. Graham v. Northshore Sch. Dist. 417, 99 Wn.2d 232 , 662 P.2d 38 (1983). This is so even if the court, as draftsman, might have used or preferred a different choice of language than that employed by the Legislature. Guinness v. State, 40 Wn.2d 677 , 246 P.2d 433 (1952). In the present case, the language of subsection (d), paragraph (2) is plain and free from ambiguity. The 10-year requirement set forth here is clearly made applicable to the entire section 1408 by the language "under this section". The majority's assertion that it could apply either to the entire section 1408 or only to subsection (d) is simply not supportable under this language. "Section" is defined as a distinct part or portion of a writing as a subdivision of a chapter. Webster's Third New International Dictionary 2052 (1961). Section 1408 is within chapter 71 and is a subdivision of this chapter. Subsection (d) is a further division of section 1408; subsection (d) is not properly termed a " section". An examination of the statute itself is conclusive proof that the word "section" encompasses every part of section 1408(a) through (h). The introductory language states: Sec. 1002. (a) Chapter 71 of title 10, United States Code, is amended by adding at the end thereof the following new section: 96 Stat. 730 , Pub. L. No. 97-252 (1982). Thereafter there follows in quotation marks all of section 1408(a) through *481 (h). In other words, the introductory language itself defines "section" by stating that there is added a new section. What is contained within that section is indicated by the quotation marks in front of "§ 1408" through the last word in (h). The entire section 1408 is the new section. Because the phrase "under this section" can only apply to the entire section 1408, no ambiguity exists and therefore statutory construction is improper. The Legislature's use of the words "section" and "subsection" in the entirety of section 1408 supports the contention that the 10-year requirement of subsection (d)(2) applies to the entire section 1408. When construing a statute, courts must read the act as a whole and not piecemeal. State v. Parker, 97 Wn.2d 737 , 649 P.2d 637 (1982); Burlington N., Inc. v. Johnston, 89 Wn.2d 321 , 572 P.2d 1085 (1977). Throughout section 1408 the Legislature used the term "section" to refer to the entire act. For example, the codification index of chapter 71 of Title 10 lists the sections of the chapter. Section 1408 is listed under the heading "sections". We can therefore presume it knew to what that term correctly referred. In addition, specific subsections are referred to. In section 1408(b)(1)(A) and in section 1408(f)(1) and (2) the term "subsection" is used to refer to subsection (h). In section 1408(d)(2) itself subsection (c) is referred to. In section 1408(d)(5) the division of paragraph is referred to, supporting further distinction between sections, subsections, and paragraphs. And most importantly, the subsection in question, subsection (d), is correctly referred to as "subsection" in section 1408(e)(1). It is obvious that the Legislature knew the difference between "section" and "subsection" and had it wanted to limit the 10-year requirement to subsection (d) it would have used the proper term. If the majority is correct in its conclusion that the limitation in section 1408(d)(2) is limited only to direct payments made under section 1408(d)(1), then the whole act is rendered a shambles. For example, section 1408(a)(1) *482 through (6) provides the definitions of the words "court", "court order", "final decree", "disposable retired or retainer pay", "member" and "spouse or former spouse". Under the majority's analysis these terms would apply only to section 1408(a). Thus, the definitions therein provided would stand alone and section 1408(a) would be meaningless. Likewise, section 1408(b) which determines when service of a court order is effective and when it is regular on its face would apply only to itself and would stand as a meaningless collection of words, applicable to nothing. In addition, section 1408(h) is utterly meaningless under the majority's analysis. In its entirety it provides: "[t]he Secretaries concerned shall prescribe uniform regulations for the administration of this section." The majority's holding would limit such regulations to the administration of section 1408(h) which only authorizes the issuances of regulations. Obviously, each subsection cannot refer solely to itself. The language "under this section" must refer to the entire section 1408 or the act is rendered useless. For example, the trial court disposed of the military pension by court order. The court order must fulfill the requirements of subsection (a)(2) before the military retired payments may be divided. The court order in this case is the very type of order section 1408 is designed to deal with. Then subsection (c) comes into play by announcing that such division is possible. And finally subsection (d) limits the division in various ways. The subsections are meant to work together and each is designed to apply to the entire section 1408. It may well be that the conference report, cited by the majority, is what the members of the conference committee intended. However, that is not what the drafter of the bill itself put into the document ultimately passed. The interpretation which applies the 10-year requirement of subsection (d)(2) to the entire statute is reconcilable with the intent apparent in the remainder of the statute. The idea that the Legislature wanted to limit state courts' authority to divide military retired pay to cases *483 where the marriages lasted a reasonable period of time fits into the general scheme of offering some protection to the retiring spouse. Section 1408(c)(3) similarly protects this spouse by not giving courts the authority to order the service member spouse to retire or apply for retirement so as to effectuate payment under section 1408. Subsection (d) provides for various limitations which protect the retiring spouse to an extent. Subsection (d), paragraph (1) requires a court order before benefits can be paid directly to the spouse or former spouse. Subsection (d), paragraph (3) provides that a court may not order payments to be made more often than cice each month. Any payment, direct or other, would occur most beneficially for both spouses at a time when money was available, after the government's monthly payment. Subsection (d), paragraph (4) limits payment under section 1408 to the time when the retired or retiring spouse is still alive. Subsection (d), paragraph (5) sets forth the procedure for garnishment of the military retired pay. Each of these paragraphs of subsection (d) refer to the "section" and each is reconcilable to the interpretation that they limit the entire section 1408. Contrary to the holding in In re Marriage of Wood, 66 Or. App. 941 , 676 P.2d 338 (1984), the limitation in (d)(1), requiring a court order before benefits are paid directly to the spouse or former spouse, is not necessarily applicable to the entire subsection (d). Each of the paragraphs are separate limitations on section 1408. Because there is no ambiguity in subsection (d) and the ordinary meaning applied to the questioned term is reconcilable with the remainder of the statute, I would hold that the 10-year requirement of subsection (d)(2) applies to the entire act. Therefore, I would reverse and remand. Dolliver, J., concurs with Brachtenbach, J. Reconsideration denied February 15, 1985. Case-law data current through December 31, 2025. Source: CourtListener bulk data . A public interest project of Aaron Hall, Attorney at Law © 2026 About Federal Minnesota California New York Texas Terms Data from CourtListener / Free Law Project ↑ \ No newline at end of file diff --git a/.research/kraft.html b/.research/kraft.html new file mode 100644 index 0000000..93ac0e8 --- /dev/null +++ b/.research/kraft.html @@ -0,0 +1,160 @@ +In Re the Marriage of Kraft, 832 P.2d 871 (Wash. 1992) | HallApproved.com
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Washington Supreme Court, 1992 +

In Re the Marriage of Kraft

In Re the Marriage of Kraft
Washington Supreme Court · Decided July 23, 1992 · Guy
832 P.2d 871; 119 Wash. 2d 438; 1992 Wash. LEXIS 201 +(Pacific Reporter, Second Series)

In Re the Marriage of Kraft

Opinion

Guy, J.

The issue here presented is whether the trial court properly applied +Mansell v. Mansell, +490 U.S. 581, 104 L. Ed. 2d 675, 109 S. Ct. 2023 (1989) in its distribution of assets in the dissolution decree. We conclude the trial court improperly considered the husband's military disability retirement pay as an asset of the community. Accordingly, we affirm the Court of Appeals and reverse and remand to the trial court for reconsideration of the property distribution in accordance with this opinion.

Facts

Bryce and Donna Kraft were married on September 23, 1967. They have two children, Troy and Karen, who were 17 and 13 years of age, respectively, at the time their parents separated on March 20, 1988. Troy and Karen remained with Mrs. Kraft at the parties' Colville residence after the separation. Mr. Kraft moved into a hunting cabin without water, electricity, or telephone.

Mrs. Kraft has a master's degree in counseling. At the time of trial she was working as an alcohol and drug abuse counselor and earning approximately $1,700 net per month.

Mr. Kraft is a retired military officer, having a combined service of 21 years at the time of retirement. During a portion of his service, Mr. Kraft was in Vietnam flying helicopters. He sustained injuries while serving in Vietnam, including bullet wounds and hearing loss. The Veterans Administration (VA) rated Mr. Kraft as being 50 percent disabled. Besides his military background, Mr. Kraft has a +*441 +bachelor's degree in elementary education and has a certificate to teach. He also has a master's degree in counseling.

Mr. Kraft's employment, as presented to the trial court, was as caretaker for an elderly man. In that capacity, he was earning at the time of trial approximately $1,000 per month. Because of the tenuous nature of this employment, the trial court found that Mr. Kraft's average net income from his caretaker job was $500 per month. Mr. Kraft also receives military benefits of $1,317 per month based on his 21 years in the service. He was married to Mrs. Kraft during 14 of those 21 years. The parties stipulated that one-half of Mr. Kraft's monthly military benefits represents disability pay.

The trial court awarded to Mr. Kraft his individual retirement account (IRA) worth $9,000, a tractor worth $800, a 1976 Mercedes automobile worth $2,500, his tools worth $1,000, his guns worth $1,000, and various items not valued. As for the parties' debts, the court ordered Mr. Kraft to be responsible for repaying the VA for his disability overpayment, which the court estimated at approximately $21,000 when he began repaying it in 1987. The court also ordered Mr. Kraft to repay one-half of the parties' $3,500 debt to their son and one-half of their $1,200 debt to their daughter. The court ordered Mr. Kraft to pay $300 per month to Mrs. Kraft as child support for Karen until Karen reaches 18 years of age (which will occur in July 1992) and left open the question of postmajority support for Karen. The court also ordered Mr. Kraft to pay Troy $200 per month for 36 months in order to assist Troy with college expenses. The court conditioned these payments upon Troy's satisfactory academic performance.

The trial court awarded to Mrs. Kraft the following: the parties' house in Colville, valued at $126,000 and subject to a $60,000 mortgage; the parties' rental property in Alabama, valued at $55,000 and subject to a $16,000 mortgage; a 1979 Volvo automobile valued at $2,500; various +*442 +items of furniture and appliances worth $7,000; Mrs. Kraft's IRA worth $8,000; Mrs. Kraft's pension worth $3,000; woodworking tools worth $1,500; and various items not valued. The court ordered that Mrs. Kraft retain whatever rental income was left over from the Alabama property after the mortgage was paid (usually $200 per month). As her share of the debts, the trial court ordered Mrs. Kraft to pay the mortgages on the houses she was awarded, to repay a bank loan of $1,800, to pay the other half of the parties' debts to Troy and Karen, and to repay a $1,000 loan from her father.

The trial court, relying on expert testimony, determined that Mr. Kraft's total military pension had a present value of $247,553. The court awarded to Mr. Kraft one-half of the value of the total pension, or approximately $123,800, as his disability pay. The court determined that two-thirds of the remaining half (rounded to $82,600) was community property, based on the fact that the parties were married for 14 of the 21 years Mr. Kraft was in the service. Accordingly, the court awarded half of the community interest, or approximately $41,300, to Mrs. Kraft.

The trial court calculated that when the present values of the military benefits (disability and retirement) are added to the amounts awarded under the property distribution, and when the debts are deducted, Mr. Kraft would receive roughly $200,000 and Mrs. Kraft roughly $162,000.

The Court of Appeals held that the trial court erroneously treated Mr. Kraft's military disability pay as an asset subject to distribution, contrary to the United States Supreme Court's holding in +Mansell v. Mansell, +490 U.S. 581, 104 L. Ed. 2d 675, 109 S. Ct. 2023 (1989). +In re Marriage of Kraft, +61 Wn. App. 45, 808 P.2d 1176 (1991). The Court of Appeals declared that when the disability pay is properly eliminated from the distribution equation, the result is a grossly disproportionate share of the parties' assets being awarded to Mrs. Kraft. 61 Wn. App. at 50. Accordingly, the Court of Appeals reversed and remanded for redistribution of assets and recomputation of child and postmajority support. This court accepted Mrs. Kraft's petition for review.

*443 +Issue

The primary issue presented is whether the trial court improperly considered Mr. Kraft's military disability retirement pay in distributing the parties' assets given the +Man-sell +holding.

Analysis

I

Persons who serve in the military for an extended period, usually at least 20 years, are entitled to retirement pay. +E.g., +10 U.S.C. § 3911 +et seq. +(1988) (Army); § 8911 +et seq. +(Air Force). Veterans are also entitled to disability benefits if they became disabled as a result of military service. 38 U.S.C. § 310 (1988) (wartime); § 331 (peacetime). A veteran may not receive both full retirement pay and disability pay, however. A retiree may receive disability benefits only to the extent that he or she waives a corresponding amount of military retirement pay. 38 U.S.C. § 3105 (1988). Such waivers are advantageous to retirees because disability benefits, unlike retirement pay, are exempt from federal, state, and local taxes. 38 U.S.C. § 3101(a) (1988).

In 1981, the United States Supreme Court held, in +McCarty v. McCarty, +453 U.S. 210, 69 L. Ed. 2d 589, 101 S. Ct. 2728 (1981), that federal law precluded a state court, upon the dissolution of a marriage, from dividing military +retirement +pay pursuant to state community property laws. Disability pay was not at issue. The Court reasoned that Congress intended military retirement pay to reach the veteran and no one else, and that therefore treating such pay as community property would do clear damage to important military personnel objectives. 453 U.S. at 232-35.

Congress responded to +McCarty +in 1982 by enacting the Uniformed Services Former Spouses' Protection Act (USFSPA), which authorizes state courts to treat "disposable retired or retainer pay" as community property subject to division upon dissolution of a marriage. 10 U.S.C. § 1408(c)(1) (1988). "Disposable retired or retainer pay" is defined in the USFSPA to exclude, +inter alia, +any amounts +*444 +waived in order to receive disability benefits. 10 U.S.C. § 1408(a)(4)(B) (1988).

In +Mansell v. Mansell, supra, +the Court addressed the question whether state courts may treat, as property divisible upon divorce, military retirement pay waived by the retiree in order to receive veterans' disability benefits. The Court held that state courts may not do so. The Court drew this conclusion from the fact that the USFSPA grants state courts the authority to treat disposable retired pay as community property but specifically excludes retirement pay waived in order to receive disability pay. 490 U.S. at 589. +See generally +Note, Mansell v. Mansell: +How it Changed the Definition of Marital Property for the Military Spouse, +30 J. Fam. L. 97 (1991-1992).

In order to assess +Mansell +properly, we must contemporaneously consider RCW 26.09.080, which provides that in a dissolution proceeding the court must dispose of the parties' property in a "just and equitable" manner after considering, +inter alia, +"[t]he economic circumstances of each spouse at the time the division of property is to become effective, including the desirability of awarding the family home or the right to five therein for reasonable periods to a spouse with whom the children reside the majority of the time." Thus, +Mansell +requires the trial court not to treat military disability retirement pay as divisible, whereas RCW 26.09.080 requires the trial court to make an equitable distribution in light of the parties' postdissolution economic circumstances. The question then becomes how the trial court is to honor both these requirements.

II

Guidance is provided by a number of state court decisions. For example, in +Rothwell v. Rothwell, +775 S.W.2d 888, 891 (Tex. Ct. App. 1989), the veteran claimed that the trial court erred in awarding a disproportionate share of the marital home to his ex-wife. In upholding the property distribution, the Texas Court of Appeals rejected this argument and declared that "the trial court could consider V.A. dis +*445 +ability retirement benefits which were payable to the husband in making a just and right division of the community assets, but it could not make any division of those benefits." 775 S.W.2d at 892. Similarly, in +Bewley v. Bewley, +116 Idaho 845, 780 P.2d 596 (Ct. App. 1989), the magistrate who had divided the parties' property treated the disability pay as separate property and left it with the veteran. The magistrate then awarded the spouse "more than her share of the community property, partially offsetting the disability pay retained by Mr. Bewley." 116 Idaho at 846. The Idaho Court of Appeals affirmed the property distribution. 116 Idaho at 847. Thus, at least two community property states have interpreted +Mansell +as permitting the trial court to consider military disability retirement pay as a factor justifying awarding a disproportionate share of the community property to the nonretiree spouse.

Some noncommunity property states have interpreted +Mansell +similarly. For example, in +Davis v. Davis, +777 S.W.2d 230 (Ky. 1989), the Supreme Court of Kentucky held that when inequity arises in divorce proceedings because of the payment of disability benefits to the military employee, the trial court may grant an increased award of spousal support or marital property. 777 S.W.2d at 232. Similarly, in +Jones v. Jones, +7 Hawaii App. 496, 780 P.2d 581 (1989), the Hawaii Intermediate Court of Appeals stated that the trial court may consider military disability retirement pay in the same way it considers each party's ability to earn income post divorce. 7 Hawaii App. at 500. +Jones +is also instructive because it shows how a trial court may go too far in considering the pay. There, the trial court had reduced the husband's military disability retirement pay to its present value, then used that value as the basis for awarding the wife other marital property of equal cash value. The Hawaii Intermediate Court of Appeals held this was error. 7 Hawaii App. at 500-01.

Other noncommunity property state courts have held that although military disability retirement pay may not be included as part of the marital estate, it may be considered as a source of income of the retiree spouse in awarding +*446 +spousal or child support. +E.g., Lambert v. Lambert, +10 Va. App. 623, 627, 395 S.E.2d 207 (1990); +Riley v. Riley, +82 Md. App. 400, 409-10, 571 A.2d 1261 (1990). In +Murphy v. Murphy, +302 Ark. 157, 787 S.W.2d 684 (1990), the Supreme Court of Arkansas went so far as to uphold an award of spousal support to a nonretiree spouse where the retiree spouse's only source of income was military disability retirement pay. The court explained that the nonretiree spouse was not entitled to direct payments for alimony under the USFSPA, but that federal law did not preclude the trial court from awarding alimony or relieve the husband from paying alimony out of his military disability retirement pay once he had received it. 302 Ark. at 159.

Ill

The cited state court decisions interpreting +Mansell +establish the general proposition that when making property distributions or awarding alimony the trial court may consider military disability retirement pay as future income of the retiree spouse relevant to a determination of the parties' ultimate economic circumstances. This rule is consistent with our decision in +In re Marriage of Dessauer, +97 Wn.2d 831, 650 P.2d 1099 (1982), +abandoned on other grounds in In re Marriage of Smith, +100 Wn.2d 319, 324, 669 P.2d 448 (1983). +Dessauer +arose after the United States Supreme Court decided +McCarty v. McCarty, supra, +but before Congress legislatively overruled that decision in the USFSPA. Thus at the time +Dessauer +was decided, state courts were prohibited from dividing military +nondisability +retirement pay pursuant to state community property laws.

Dessauer +involved two separate dissolution actions (Dessauer and Salerno) involving husbands with military non-disability retirement income. In each action, the husband contended that the trial court had considered his retirement income in a fashion inconsistent with +McCarty +when making the property distribution.

*447 +In the Dessauer action, the trial court had classified the retired pay as community property and divided the benefits between the parties. 97 Wn.2d at 834. We held this was improper under +McCarty, +and we remanded the action to the trial court for redistribution. 97 Wn.2d at 834. In the combined dissolution appeal of Salerno, the trial court had not classified the retirement pay as community property and had not divided it or offset other property because of it. 97 Wn.2d at 834, 836-37. Instead, the trial court had considered the fact that Mr. Salerno received a monthly income as an economic circumstance of the parties. 97 Wn.2d at 837. The trial court had discussed the value of the pension in terms of present value, but had specifically stated the court did not consider this value in dividing the remainder of the property. 97 Wn.2d at 834. We held that the Salerno trial court's action was proper under +McCarty +and explained that "[without considering the true economic circumstances of the parties before it, the court would be unable to properly exercise its discretion and make a just and equitable distribution of the property as required by [RCW 26.09.080]." +Dessauer, +at 838. We therefore concluded:

[A] court may consider military nondisability retired pay as an economic circumstance of the parties when dividing property. However, the court must not characterize the retirement income as community property or divide it. Neither may it value the pension and offset property against that value.

Dessauer, +at 839. +Accord, In re Marriage of Smith, +33 Wn. App. 147, 652 P.2d 391 (1982) +(post-McCarty +but pre-USFSPA decision holding trial court erred by awarding wife community property of comparable value in order to offset fully husband's military retirement); +In re Marriage of Roark, +34 Wn. App. 252, 659 P.2d 1133 (1983) (similar result concerning railroad retirement benefits).

The conclusion we reached in +Dessauer +accords with the general rule derived above from the more recent state court decisions interpreting +Mansell. +Accordingly, we hold that when making property distributions or awarding +*448 +spousal support in a dissolution proceeding, the court may regard military disability retirement pay as future income to the retiree spouse and, so regarded, consider it as an economic circumstance of the parties. In particular, the court may consider the pay as a basis for awarding the nonretiree spouse a proportionately larger share of the community property where equity so requires. The court may not, however, divide or distribute the military disability retirement pay as an asset. It is improper under +Mansell +for the trial court to reduce military disability pay to present value where the purpose of ascertaining present value is to serve as a basis to award the nonretiree spouse a proportionately greater share of the community property as a direct offset of assets.

IV

Applying this rule in the present case, we conclude the trial court erred by reducing Mr. Kraft's military disability retirement pay to its present value and then using that present value as the basis for awarding Mrs. Kraft a proportionately larger share of the community property as an offset of assets. The trial court reduced Mr. Kraft's entire military pension to its present value of $247,553. The court then found that half of this, or approximately $123,800, represented Mr. Kraft's disability pay and listed it along with the various other assets the court was awarding to Mr. Kraft. Adding the values of the properties the parties were to receive, and then subtracting debts, the court concluded that the property distribution would result in Mr. Kraft receiving roughly $200,000 and Mrs. Kraft roughly $162,000. This distribution would thus give Mrs. Kraft the bulk of the parties' community property as a means of offsetting the present value of Mr. Kraft's military disability retirement pay. In following this procedure the trial court effectively distributed the disability pension as an asset, contrary to the mandate of +Mansell +and contrary to the rule we have announced above.

*449 +V

We next consider whether the trial court's incorrect manner of considering the disability benefits requires remand. This question is analogous to the question raised when an appellate court determines that the trial court committed error in characterizing property as either separate or community. We have previously held that the characterization of property is not controlling and that the ultimate question is "whether the final division of the property is fair, just and equitable under all the circumstances." +Baker v. Baker, +80 Wn.2d 736, 745-46, 498 P.2d 315 (1972). However, "[r]emand is required where (1) the trial court's reasoning indicates that its division was significantly influenced by its characterization of the property, and (2) it is not clear that had the court properly characterized the property, it would have divided it in the same way." +In re Marriage of Shannon, 55 +Wn. App. 137, 142, 777 P.2d 8 (1989). Similarly, we hold that remand is appropriate where the trial court's property distribution was significantly influenced by its improper manner of considering military disability retirement pay and where there is doubt whether the trial court would have distributed the property the way it did had it properly considered the pay.

Here, the trial court attempted to achieve rough equality in its property distribution by reducing the disability benefits to present value and offsetting that value by awarding to Mrs. Kraft a proportionately greater share of community property.

The Court of Appeals also concluded that remand is required, but for a different reason. The Court of Appeals took the view that the trial court should have disregarded Mr. Kraft's military pension altogether, including both his disability and nondisability benefits. +In re Marriage of Kraft, +61 Wn. App. 45, 51-52, 808 P.2d 1176 (1991). The court then concluded that when those benefits are disregarded, the trial court's distribution would result in Mr. Kraft receiving assets worth approximately $12,000 and +*450 +Mrs. Kraft receiving assets worth approximately $122,000, which in the view of the Court of Appeals is not a just and equitable distribution. +Kraft, +at 52.

We do not agree with the Court of Appeals that the trial court should have wholly disregarded the nondisability portion of Mr. Kraft's military pension. Reducing a retirement pension to its present value is a recognized procedure in the valuation of divorce assets. +See, e.g., In re Marriage of Pilant, +42 Wn. App. 173, 179, 709 P.2d 1241 (1985). +See generally +B. Goldberg, +Valuation of Divorce Assets +§ 9.5, at 251 (1984) (explaining how to determine the present value of a pension plan for purposes of a dissolution and describing the advantages of doing so); L. Golden, +Equitable Distribution of Property +§ 7.12, at 227-28 (1983) (trial courts should be given broad discretion in valuing pension interests, and determining the present value of a pension is the most common method). The trial court did not err in reducing the nondisability portion of Mr. Kraft's military pension to its present value. Notably, the parties agree the trial court may reduce military pay to present value.

When the present value of just the disability benefits is disregarded, the net distribution of community property is roughly $76,200 to Mr. Kraft and $162,000 to Mrs. Kraft. A trial court has considerable discretion in making a property division and will not be reversed on appeal absent a showing of manifest abuse. +In re Marriage of Tower, +55 Wn. App. 697, 700, 780 P.2d 863 (1989), +review denied, +114 Wn.2d 1002 (1990). Therefore, on remand, the trial court may, if in its view equity so requires, distribute the Krafts' property in the same manner in which it did initially. What is required is that the trial court arrive at its decision as to what is just and equitable under all the circumstances after considering the military disability retirement pay in the manner we here explain.

VI

Finally, Mrs. Kraft objects to the Court of Appeals use of the term "individual property" to refer to Mr. Kraft's disability benefits. +Kraft, +at 49. Mrs. Kraft argues that in doing so +*451 +the Court of Appeals impermissibly usurped legislative power by defining a new class of "individual" property which is not subject to the rules for distribution of property on dissolution of marriage. We disagree. The court stated that it was calling the disability pay "individual property" simply to dispel any idea that military disability pay is subject to division as separate property. +Kraft, +at 49 n.2. The Court of Appeals explained that it wanted to avoid use of the term "separate property" in reference to the retirement pay because disability pay may be community property when received during marriage and may be separate property when received outside the marriage. +Kraft, +at 49 n.2. The court was not creating a new class of property.

Conclusion

We hold the trial court in a marriage dissolution action may consider military disability retirement pay as a source of income in awarding spousal or child support, or generally as an economic circumstance of the parties justifying a disproportionate award of community property to the nonretiree spouse. The trial court may not, however, divide and distribute the disability pay or value it and offset other property against that value. In the present case, the trial court reduced the military disability pay to present value and then offset assets against it by awarding to Mrs. Kraft a proportionately larger share of the community property. This is not a permissible way of considering military disability retirement pay under the +Mansell +holding.

The Court of Appeals is affirmed. We remand to the trial court for reconsideration of the properly distribution in light of this opinion.

Dore, C.J., and Utter, Brachtenbach, Dolliver, Andersen, Durham, Smith, and Johnson, JJ., concur.

Case-law data current through December 31, 2025. Source: CourtListener bulk data.

↑ + \ No newline at end of file diff --git a/.research/kraft.txt b/.research/kraft.txt new file mode 100644 index 0000000..8acf5a5 --- /dev/null +++ b/.research/kraft.txt @@ -0,0 +1 @@ +In Re the Marriage of Kraft, 832 P.2d 871 (Wash. 1992) | HallApproved.com Hall Approved Free Access to American Case Law Statutes Free Legal Archive / Washington / Cases / Washington Supreme Court / 1992 / Washington Supreme Court, 1992 Copy citation Free Legal Archive / Washington / Cases / Washington Supreme Court / 1992 / In Re the Marriage of Kraft In Re the Marriage of Kraft Washington Supreme Court · Decided July 23, 1992 · Guy 832 P.2d 871; 119 Wash. 2d 438; 1992 Wash. LEXIS 201 (Pacific Reporter, Second Series) In Re the Marriage of Kraft Opinion Guy, J. The issue here presented is whether the trial court properly applied Mansell v. Mansell, 490 U.S. 581 , 104 L. Ed. 2d 675 , 109 S. Ct. 2023 (1989) in its distribution of assets in the dissolution decree. We conclude the trial court improperly considered the husband's military disability retirement pay as an asset of the community. Accordingly, we affirm the Court of Appeals and reverse and remand to the trial court for reconsideration of the property distribution in accordance with this opinion. Facts Bryce and Donna Kraft were married on September 23, 1967. They have two children, Troy and Karen, who were 17 and 13 years of age, respectively, at the time their parents separated on March 20, 1988. Troy and Karen remained with Mrs. Kraft at the parties' Colville residence after the separation. Mr. Kraft moved into a hunting cabin without water, electricity, or telephone. Mrs. Kraft has a master's degree in counseling. At the time of trial she was working as an alcohol and drug abuse counselor and earning approximately $1,700 net per month. Mr. Kraft is a retired military officer, having a combined service of 21 years at the time of retirement. During a portion of his service, Mr. Kraft was in Vietnam flying helicopters. He sustained injuries while serving in Vietnam, including bullet wounds and hearing loss. The Veterans Administration (VA) rated Mr. Kraft as being 50 percent disabled. Besides his military background, Mr. Kraft has a *441 bachelor's degree in elementary education and has a certificate to teach. He also has a master's degree in counseling. Mr. Kraft's employment, as presented to the trial court, was as caretaker for an elderly man. In that capacity, he was earning at the time of trial approximately $1,000 per month. Because of the tenuous nature of this employment, the trial court found that Mr. Kraft's average net income from his caretaker job was $500 per month. Mr. Kraft also receives military benefits of $1,317 per month based on his 21 years in the service. He was married to Mrs. Kraft during 14 of those 21 years. The parties stipulated that one-half of Mr. Kraft's monthly military benefits represents disability pay. The trial court awarded to Mr. Kraft his individual retirement account (IRA) worth $9,000, a tractor worth $800, a 1976 Mercedes automobile worth $2,500, his tools worth $1,000, his guns worth $1,000, and various items not valued. As for the parties' debts, the court ordered Mr. Kraft to be responsible for repaying the VA for his disability overpayment, which the court estimated at approximately $21,000 when he began repaying it in 1987. The court also ordered Mr. Kraft to repay one-half of the parties' $3,500 debt to their son and one-half of their $1,200 debt to their daughter. The court ordered Mr. Kraft to pay $300 per month to Mrs. Kraft as child support for Karen until Karen reaches 18 years of age (which will occur in July 1992) and left open the question of postmajority support for Karen. The court also ordered Mr. Kraft to pay Troy $200 per month for 36 months in order to assist Troy with college expenses. The court conditioned these payments upon Troy's satisfactory academic performance. The trial court awarded to Mrs. Kraft the following: the parties' house in Colville, valued at $126,000 and subject to a $60,000 mortgage; the parties' rental property in Alabama, valued at $55,000 and subject to a $16,000 mortgage; a 1979 Volvo automobile valued at $2,500; various *442 items of furniture and appliances worth $7,000; Mrs. Kraft's IRA worth $8,000; Mrs. Kraft's pension worth $3,000; woodworking tools worth $1,500; and various items not valued. The court ordered that Mrs. Kraft retain whatever rental income was left over from the Alabama property after the mortgage was paid (usually $200 per month). As her share of the debts, the trial court ordered Mrs. Kraft to pay the mortgages on the houses she was awarded, to repay a bank loan of $1,800, to pay the other half of the parties' debts to Troy and Karen, and to repay a $1,000 loan from her father. The trial court, relying on expert testimony, determined that Mr. Kraft's total military pension had a present value of $247,553. The court awarded to Mr. Kraft one-half of the value of the total pension, or approximately $123,800, as his disability pay. The court determined that two-thirds of the remaining half (rounded to $82,600) was community property, based on the fact that the parties were married for 14 of the 21 years Mr. Kraft was in the service. Accordingly, the court awarded half of the community interest, or approximately $41,300, to Mrs. Kraft. The trial court calculated that when the present values of the military benefits (disability and retirement) are added to the amounts awarded under the property distribution, and when the debts are deducted, Mr. Kraft would receive roughly $200,000 and Mrs. Kraft roughly $162,000. The Court of Appeals held that the trial court erroneously treated Mr. Kraft's military disability pay as an asset subject to distribution, contrary to the United States Supreme Court's holding in Mansell v. Mansell, 490 U.S. 581 , 104 L. Ed. 2d 675 , 109 S. Ct. 2023 (1989). In re Marriage of Kraft, 61 Wn. App. 45 , 808 P.2d 1176 (1991). The Court of Appeals declared that when the disability pay is properly eliminated from the distribution equation, the result is a grossly disproportionate share of the parties' assets being awarded to Mrs. Kraft. 61 Wn. App. at 50 . Accordingly, the Court of Appeals reversed and remanded for redistribution of assets and recomputation of child and postmajority support. This court accepted Mrs. Kraft's petition for review. *443 Issue The primary issue presented is whether the trial court improperly considered Mr. Kraft's military disability retirement pay in distributing the parties' assets given the Man-sell holding. Analysis I Persons who serve in the military for an extended period, usually at least 20 years, are entitled to retirement pay. E.g., 10 U.S.C. § 3911 et seq. (1988) (Army); § 8911 et seq. (Air Force). Veterans are also entitled to disability benefits if they became disabled as a result of military service. 38 U.S.C. § 310 (1988) (wartime); § 331 (peacetime). A veteran may not receive both full retirement pay and disability pay, however. A retiree may receive disability benefits only to the extent that he or she waives a corresponding amount of military retirement pay. 38 U.S.C. § 3105 (1988). Such waivers are advantageous to retirees because disability benefits, unlike retirement pay, are exempt from federal, state, and local taxes. 38 U.S.C. § 3101 (a) (1988). In 1981, the United States Supreme Court held, in McCarty v. McCarty, 453 U.S. 210 , 69 L. Ed. 2d 589 , 101 S. Ct. 2728 (1981), that federal law precluded a state court, upon the dissolution of a marriage, from dividing military retirement pay pursuant to state community property laws. Disability pay was not at issue. The Court reasoned that Congress intended military retirement pay to reach the veteran and no one else, and that therefore treating such pay as community property would do clear damage to important military personnel objectives. 453 U.S. at 232-35 . Congress responded to McCarty in 1982 by enacting the Uniformed Services Former Spouses' Protection Act (USFSPA), which authorizes state courts to treat "disposable retired or retainer pay" as community property subject to division upon dissolution of a marriage. 10 U.S.C. § 1408 (c)(1) (1988). "Disposable retired or retainer pay" is defined in the USFSPA to exclude, inter alia, any amounts *444 waived in order to receive disability benefits. 10 U.S.C. § 1408 (a)(4)(B) (1988). In Mansell v. Mansell, supra, the Court addressed the question whether state courts may treat, as property divisible upon divorce, military retirement pay waived by the retiree in order to receive veterans' disability benefits. The Court held that state courts may not do so. The Court drew this conclusion from the fact that the USFSPA grants state courts the authority to treat disposable retired pay as community property but specifically excludes retirement pay waived in order to receive disability pay. 490 U.S. at 589 . See generally Note, Mansell v. Mansell: How it Changed the Definition of Marital Property for the Military Spouse, 30 J. Fam. L. 97 (1991-1992). In order to assess Mansell properly, we must contemporaneously consider RCW 26.09.080, which provides that in a dissolution proceeding the court must dispose of the parties' property in a "just and equitable" manner after considering, inter alia, "[t]he economic circumstances of each spouse at the time the division of property is to become effective, including the desirability of awarding the family home or the right to five therein for reasonable periods to a spouse with whom the children reside the majority of the time." Thus, Mansell requires the trial court not to treat military disability retirement pay as divisible, whereas RCW 26.09.080 requires the trial court to make an equitable distribution in light of the parties' postdissolution economic circumstances. The question then becomes how the trial court is to honor both these requirements. II Guidance is provided by a number of state court decisions. For example, in Rothwell v. Rothwell, 775 S.W.2d 888, 891 (Tex. Ct. App. 1989), the veteran claimed that the trial court erred in awarding a disproportionate share of the marital home to his ex-wife. In upholding the property distribution, the Texas Court of Appeals rejected this argument and declared that "the trial court could consider V.A. dis *445 ability retirement benefits which were payable to the husband in making a just and right division of the community assets, but it could not make any division of those benefits." 775 S.W.2d at 892 . Similarly, in Bewley v. Bewley, 116 Idaho 845 , 780 P.2d 596 (Ct. App. 1989), the magistrate who had divided the parties' property treated the disability pay as separate property and left it with the veteran. The magistrate then awarded the spouse "more than her share of the community property, partially offsetting the disability pay retained by Mr. Bewley." 116 Idaho at 846 . The Idaho Court of Appeals affirmed the property distribution. 116 Idaho at 847 . Thus, at least two community property states have interpreted Mansell as permitting the trial court to consider military disability retirement pay as a factor justifying awarding a disproportionate share of the community property to the nonretiree spouse. Some noncommunity property states have interpreted Mansell similarly. For example, in Davis v. Davis, 777 S.W.2d 230 (Ky. 1989), the Supreme Court of Kentucky held that when inequity arises in divorce proceedings because of the payment of disability benefits to the military employee, the trial court may grant an increased award of spousal support or marital property. 777 S.W.2d at 232 . Similarly, in Jones v. Jones, 7 Hawaii App. 496 , 780 P.2d 581 (1989), the Hawaii Intermediate Court of Appeals stated that the trial court may consider military disability retirement pay in the same way it considers each party's ability to earn income post divorce. 7 Hawaii App. at 500 . Jones is also instructive because it shows how a trial court may go too far in considering the pay. There, the trial court had reduced the husband's military disability retirement pay to its present value, then used that value as the basis for awarding the wife other marital property of equal cash value. The Hawaii Intermediate Court of Appeals held this was error. 7 Hawaii App. at 500-01 . Other noncommunity property state courts have held that although military disability retirement pay may not be included as part of the marital estate, it may be considered as a source of income of the retiree spouse in awarding *446 spousal or child support. E.g., Lambert v. Lambert, 10 Va. App. 623, 627 , 395 S.E.2d 207 (1990); Riley v. Riley, 82 Md. App. 400, 409-10 , 571 A.2d 1261 (1990). In Murphy v. Murphy, 302 Ark. 157 , 787 S.W.2d 684 (1990), the Supreme Court of Arkansas went so far as to uphold an award of spousal support to a nonretiree spouse where the retiree spouse's only source of income was military disability retirement pay. The court explained that the nonretiree spouse was not entitled to direct payments for alimony under the USFSPA, but that federal law did not preclude the trial court from awarding alimony or relieve the husband from paying alimony out of his military disability retirement pay once he had received it. 302 Ark. at 159 . Ill The cited state court decisions interpreting Mansell establish the general proposition that when making property distributions or awarding alimony the trial court may consider military disability retirement pay as future income of the retiree spouse relevant to a determination of the parties' ultimate economic circumstances. This rule is consistent with our decision in In re Marriage of Dessauer, 97 Wn.2d 831 , 650 P.2d 1099 (1982), abandoned on other grounds in In re Marriage of Smith, 100 Wn.2d 319, 324 , 669 P.2d 448 (1983). Dessauer arose after the United States Supreme Court decided McCarty v. McCarty, supra, but before Congress legislatively overruled that decision in the USFSPA. Thus at the time Dessauer was decided, state courts were prohibited from dividing military nondisability retirement pay pursuant to state community property laws. Dessauer involved two separate dissolution actions (Dessauer and Salerno) involving husbands with military non-disability retirement income. In each action, the husband contended that the trial court had considered his retirement income in a fashion inconsistent with McCarty when making the property distribution. *447 In the Dessauer action, the trial court had classified the retired pay as community property and divided the benefits between the parties. 97 Wn.2d at 834 . We held this was improper under McCarty , and we remanded the action to the trial court for redistribution. 97 Wn.2d at 834 . In the combined dissolution appeal of Salerno, the trial court had not classified the retirement pay as community property and had not divided it or offset other property because of it. 97 Wn.2d at 834, 836-37 . Instead, the trial court had considered the fact that Mr. Salerno received a monthly income as an economic circumstance of the parties. 97 Wn.2d at 837 . The trial court had discussed the value of the pension in terms of present value, but had specifically stated the court did not consider this value in dividing the remainder of the property. 97 Wn.2d at 834 . We held that the Salerno trial court's action was proper under McCarty and explained that "[without considering the true economic circumstances of the parties before it, the court would be unable to properly exercise its discretion and make a just and equitable distribution of the property as required by [RCW 26.09.080]." Dessauer, at 838. We therefore concluded: [A] court may consider military nondisability retired pay as an economic circumstance of the parties when dividing property. However, the court must not characterize the retirement income as community property or divide it. Neither may it value the pension and offset property against that value. Dessauer, at 839. Accord, In re Marriage of Smith, 33 Wn. App. 147 , 652 P.2d 391 (1982) (post-McCarty but pre-USFSPA decision holding trial court erred by awarding wife community property of comparable value in order to offset fully husband's military retirement); In re Marriage of Roark, 34 Wn. App. 252 , 659 P.2d 1133 (1983) (similar result concerning railroad retirement benefits). The conclusion we reached in Dessauer accords with the general rule derived above from the more recent state court decisions interpreting Mansell . Accordingly, we hold that when making property distributions or awarding *448 spousal support in a dissolution proceeding, the court may regard military disability retirement pay as future income to the retiree spouse and, so regarded, consider it as an economic circumstance of the parties. In particular, the court may consider the pay as a basis for awarding the nonretiree spouse a proportionately larger share of the community property where equity so requires. The court may not, however, divide or distribute the military disability retirement pay as an asset. It is improper under Mansell for the trial court to reduce military disability pay to present value where the purpose of ascertaining present value is to serve as a basis to award the nonretiree spouse a proportionately greater share of the community property as a direct offset of assets. IV Applying this rule in the present case, we conclude the trial court erred by reducing Mr. Kraft's military disability retirement pay to its present value and then using that present value as the basis for awarding Mrs. Kraft a proportionately larger share of the community property as an offset of assets. The trial court reduced Mr. Kraft's entire military pension to its present value of $247,553. The court then found that half of this, or approximately $123,800, represented Mr. Kraft's disability pay and listed it along with the various other assets the court was awarding to Mr. Kraft. Adding the values of the properties the parties were to receive, and then subtracting debts, the court concluded that the property distribution would result in Mr. Kraft receiving roughly $200,000 and Mrs. Kraft roughly $162,000. This distribution would thus give Mrs. Kraft the bulk of the parties' community property as a means of offsetting the present value of Mr. Kraft's military disability retirement pay. In following this procedure the trial court effectively distributed the disability pension as an asset, contrary to the mandate of Mansell and contrary to the rule we have announced above. *449 V We next consider whether the trial court's incorrect manner of considering the disability benefits requires remand. This question is analogous to the question raised when an appellate court determines that the trial court committed error in characterizing property as either separate or community. We have previously held that the characterization of property is not controlling and that the ultimate question is "whether the final division of the property is fair, just and equitable under all the circumstances." Baker v. Baker, 80 Wn.2d 736, 745-46 , 498 P.2d 315 (1972). However, "[r]emand is required where (1) the trial court's reasoning indicates that its division was significantly influenced by its characterization of the property, and (2) it is not clear that had the court properly characterized the property, it would have divided it in the same way." In re Marriage of Shannon, 55 Wn. App. 137, 142, 777 P.2d 8 (1989). Similarly, we hold that remand is appropriate where the trial court's property distribution was significantly influenced by its improper manner of considering military disability retirement pay and where there is doubt whether the trial court would have distributed the property the way it did had it properly considered the pay. Here, the trial court attempted to achieve rough equality in its property distribution by reducing the disability benefits to present value and offsetting that value by awarding to Mrs. Kraft a proportionately greater share of community property. The Court of Appeals also concluded that remand is required, but for a different reason. The Court of Appeals took the view that the trial court should have disregarded Mr. Kraft's military pension altogether, including both his disability and nondisability benefits. In re Marriage of Kraft, 61 Wn. App. 45, 51-52 , 808 P.2d 1176 (1991). The court then concluded that when those benefits are disregarded, the trial court's distribution would result in Mr. Kraft receiving assets worth approximately $12,000 and *450 Mrs. Kraft receiving assets worth approximately $122,000, which in the view of the Court of Appeals is not a just and equitable distribution. Kraft, at 52. We do not agree with the Court of Appeals that the trial court should have wholly disregarded the nondisability portion of Mr. Kraft's military pension. Reducing a retirement pension to its present value is a recognized procedure in the valuation of divorce assets. See, e.g., In re Marriage of Pilant, 42 Wn. App. 173, 179 , 709 P.2d 1241 (1985). See generally B. Goldberg, Valuation of Divorce Assets § 9.5, at 251 (1984) (explaining how to determine the present value of a pension plan for purposes of a dissolution and describing the advantages of doing so); L. Golden, Equitable Distribution of Property § 7.12, at 227-28 (1983) (trial courts should be given broad discretion in valuing pension interests, and determining the present value of a pension is the most common method). The trial court did not err in reducing the nondisability portion of Mr. Kraft's military pension to its present value. Notably, the parties agree the trial court may reduce military pay to present value. When the present value of just the disability benefits is disregarded, the net distribution of community property is roughly $76,200 to Mr. Kraft and $162,000 to Mrs. Kraft. A trial court has considerable discretion in making a property division and will not be reversed on appeal absent a showing of manifest abuse. In re Marriage of Tower, 55 Wn. App. 697, 700 , 780 P.2d 863 (1989), review denied, 114 Wn.2d 1002 (1990). Therefore, on remand, the trial court may, if in its view equity so requires, distribute the Krafts' property in the same manner in which it did initially. What is required is that the trial court arrive at its decision as to what is just and equitable under all the circumstances after considering the military disability retirement pay in the manner we here explain. VI Finally, Mrs. Kraft objects to the Court of Appeals use of the term "individual property" to refer to Mr. Kraft's disability benefits. Kraft, at 49. Mrs. Kraft argues that in doing so *451 the Court of Appeals impermissibly usurped legislative power by defining a new class of "individual" property which is not subject to the rules for distribution of property on dissolution of marriage. We disagree. The court stated that it was calling the disability pay "individual property" simply to dispel any idea that military disability pay is subject to division as separate property. Kraft, at 49 n.2. The Court of Appeals explained that it wanted to avoid use of the term "separate property" in reference to the retirement pay because disability pay may be community property when received during marriage and may be separate property when received outside the marriage. Kraft, at 49 n.2. The court was not creating a new class of property. Conclusion We hold the trial court in a marriage dissolution action may consider military disability retirement pay as a source of income in awarding spousal or child support, or generally as an economic circumstance of the parties justifying a disproportionate award of community property to the nonretiree spouse. The trial court may not, however, divide and distribute the disability pay or value it and offset other property against that value. In the present case, the trial court reduced the military disability pay to present value and then offset assets against it by awarding to Mrs. Kraft a proportionately larger share of the community property. This is not a permissible way of considering military disability retirement pay under the Mansell holding. The Court of Appeals is affirmed. We remand to the trial court for reconsideration of the properly distribution in light of this opinion. Dore, C.J., and Utter, Brachtenbach, Dolliver, Andersen, Durham, Smith, and Johnson, JJ., concur. Case-law data current through December 31, 2025. Source: CourtListener bulk data . A public interest project of Aaron Hall, Attorney at Law © 2026 About Federal Minnesota California New York Texas Terms Data from CourtListener / Free Law Project ↑ \ No newline at end of file diff --git a/.research/olivares.txt b/.research/olivares.txt new file mode 100644 index 0000000..45ac240 --- /dev/null +++ b/.research/olivares.txt @@ -0,0 +1 @@ +MATTER OF MARRIAGE OF OLI | 69 Wn. App... | napp3241358 | Leagle.com Menu Home Featured Decisions Latest Decisions Browse Decisions Advanced Search Sign in Home Browse Decisions Wn. 69 Wn. 69 Wn. App. 324 (1993) MATTER OF MARRIAGE OF OLIVARES No. 28758-3-I. View Case 69 Wn. App. 324 (1993) 848 P.2d 1281 In the Matter of the Marriage of STEPHEN R. OLIVARES, Appellant, and THERESA R. OLIVARES, Respondent. The Court of Appeals of Washington, Division One. https://leagle.com/images/logo.png April 12, 1993. April 12, 1993. Attorney(s) appearing for the Case Philip A. Talmadge, Celeste A. McDonell, and Talmadge & Cutler, P.S.; Thomas D. Bigsby and Bigsby & Willson, for appellant. Jerome L. Jager and Donna McNamara, for respondent. The Court of Appeals of Washington, Division One. KENNEDY, J. This appeal arises out of the dissolution of the marriage of appellant Stephen R. Olivares and respondent Theresa R. Olivares. Stephen appeals the trial court's characterization and distribution of a classic white Ford Mustang automobile and a promissory note/deed of trust. We affirm. FACTS Stephen and Theresa Olivares met when Theresa responded to a newspaper ad placed by Stephen in the Little... Let's get started Welcome to the leading source of independent legal reporting Sign on now to see your case. Or view more than 10 million decisions and orders. Updated daily. Uncompromising quality. Complete, Accurate, Current. Subscribe Now! Listed below are the cases that are cited in this Featured Case. Click the citation to see the full text of the cited case. Citations are also linked in the body of the Featured Case. Cited Cases No Cases Found Listed below are those cases in which this Featured Case is cited. Click on the case name to see the full text of the citing case. Citing Cases Copyright © 2026, Leagle, Inc. Disclaimer Terms of Use Privacy Statement Corporate Social Responsibility About Us Contact Us \ No newline at end of file diff --git a/.research/olivares_studicata.txt b/.research/olivares_studicata.txt new file mode 100644 index 0000000..efb60f4 --- /dev/null +++ b/.research/olivares_studicata.txt @@ -0,0 +1 @@ +In re the Marriage of Olivares 69 Wash. App. 324 (1993) Current section Background Facts And Trial Court Findings Normal Study Deep Study Exit focus mode › Smart Sections Study Controls ‹ Smart sections Study controls ‹ Opinion preview Smart Sections In re the Marriage of Olivares 69 Wash. App. 324 (1993) 01 Background Facts And Trial Court Findings 02 Legal Standards And Gift Challenge 03 Donor Intent, Presumptions, And Martin Precedent 04 Final Application: Division And Car Gift Rule 05 FOOTNOTES Unlocked sections read 0 / 3 Unlocked text 1,929 words Reading time ≈ 10 min Deep Study · Preview In re the Marriage of Olivares Read the first three unlocked smart sections with complete study tools. The remaining opinion sections are available to active Case Briefs+ subscribers. Washington Court of Appeals 69 Wash. App. 324 * 1993 Kennedy, J. Preview access 3 of 5 sections Unlocked reading time ≈ 10 min Notice This opinion may have been converted from a scanned document and could contain text errors. We corrected obvious typos and may have adjusted spacing, paragraph breaks, and formatting for readability. We did not intend to change the court’s meaning. This is not an official court copy. Page numbers and formatting may differ. Always verify quotations and citations against the official opinion. Studicata smart section • This header is not part of the opinion Kennedy, J. majority Background Facts And Trial Court Findings 788 words • ≈ 4 min 01 Summarize Simplify Copy source text Mark read Collapse Section summary Stephen and Theresa Olivares married in December 1988, lived largely off Stephen's assets and gifts from his parents, and separated in August 1990. In early 1989 Stephen's parents, via escrow, assigned a promissory note/deed of trust (about $235,000; $2,000/month for 27 years) and added Theresa's name on the documents. Stephen bought a 1968 white Mustang on his separate credit but placed title in Theresa's name. The trial court found the note a gift to both spouses (community property, divided 50/50) and the Mustang a gift to Theresa (community property), and Stephen appealed. This summary is added by Studicata. Switch back to view the complete source text for this section. Simplified section Marriage: Dec. 22, 1988 to Aug. 1, 1990 separation; most of marriage spent traveling and working on Stephen's Arlington house. Stephen's pre-marriage assets included rental property, a house under construction, and a car collection; Theresa brought minimal assets. Stephen's parents transferred an assigned promissory note via escrow; escrow added Theresa's name and payments were routed to an account listing both spouses' SSNs. Parents testified they intended beneficiaries to share in the proceeds while married and did not state any condition that the gift would end if the marriage ended. Stephen purchased the 1968 Mustang on his separate credit but placed the title in Theresa's name; he claimed it was not a gift. Trial court findings: promissory note characterized as a gift to both spouses (awarded one-half each); Mustang found to be a gift to Theresa (awarded to her). These simplified bullets are added by Studicata. Switch back to view the complete source text for this section. Kennedy, J. This appeal arises out of the dissolution of the marriage of appellant Stephen R. Olivares and respondent [*326] Theresa R. Olivares. Stephen appeals the trial court's characterization and distribution of a classic white Ford Mustang automobile and a promissory note/deed of trust. We affirm. Facts Stephen and Theresa Olivares met when Theresa responded to a newspaper ad placed by Stephen in the Little Nickel Want Ads. Theresa was in her late forties and Stephen was in his early fifties. When the parties met, Theresa's second divorce was not yet final. The couple dated for about 6 months and married on December 22, 1988, in the state of Arizona. This was the third marriage for each party and both parties have adult children from prior marriages. At the time of the marriage, Stephen, who is a carpenter by trade, had substantial property. His assets included a rental house in Arlington, Washington, a house under construction in Arlington and a car collection. Theresa's assets at the time of marriage were limited to an old car, a $1,000 certificate of deposit, and $3,000 in cash. From the time of their marriage in December 1988, until their separation on August 1, 1990, neither party was employed. The majority of the marriage was spent traveling outside of the United States on an extended honeymoon and on vacations to the southwestern United States, Hawaii and Mexico, paid for by Stephen's parents. When the couple was not traveling they worked together on the Arlington house, which was substantially completed during the marriage. During their marriage, the Olivares lived off the proceeds of the sale of Stephen's rental house and on gifts and loans from-his parents. The couple also borrowed money from Theresa's children. In early 1989, in an attempt to simplify their affairs, Stephen's elderly parents transferred three trust deeds, one to each of their sons and their sons' wives. Stephen and Theresa were assigned the proceeds of a promissory note/ deed of trust worth about $235,000. The note at issue here pays $2,000 per month for 27 years. [*327] The assignment was accomplished through an escrow company in California, without the assistance of an attorney. Initially, the parents were making the assignment to Stephen. However, the escrow agent added Theresa's name to the transfer documents, explaining to Stephen and his parents that it was "required by law" to include both the husband and wife as joint tenants. [Footnote 1] Footnote 1: The parties have not briefed California law on this matter. Certainly the proposition sounds foreign to Washington lawyers and judges. Mildred Olivares, Stephen's mother, testified that the purpose of the gifts was to give her three sons and their children part of their inheritance. She also stated, however, that she knew that Theresa's name was included on the assignment and that Theresa would benefit from the gift, as it was expected that Theresa and Stephen would five on the proceeds. Mildred also indicated that she had not considered that her son and Theresa might not stay married and that she had never told Theresa that the gift to her was conditioned upon her and Stephen remaining married. The payments were set up to go into an escrow account, with both Stephen's and Theresa's Social Security numbers on the account. Prior to the couple's marital difficulties, no one ever indicated to Theresa that the assignment of the contract was not for her benefit. Theresa testified that Stephen's parents were happy with her and happy that Stephen was finally breaking out of his depression. She testified that she was told she was to be included in the gift and that she told Stephen's parents she was very appreciative and that it was a wonderful present. During the marriage the Olivares sold Theresa's old car, a 1983 Dodge. Stephen purchased a classic white 1968 Ford Mustang with a loan based on his separate credit and placed the title in Theresa's name. Stephen contends that he placed the car's title in his wife's name so that he could sell it later that year. He testified that he had already sold as many vehicles that year as he was allowed by law without obtaining a dealer's license. Theresa asserted that the car's title was in her name because it was a gift to her. [*328] The trial court found the marriage to be irretrievably broken and granted dissolution of the marriage. The trial court found the 1968 classic white Ford Mustang to be a gift from Stephen to his wife, characterized it as community property and awarded it to Theresa. [Footnote 2] Footnote 2: Since the trial court found the car to be a gift to Theresa, the court should have characterized the car as her separate property. See Scott v. Currie, 7 Wn.2d 301, 307-08, 109 P.2d 526 (1941); Plath v. Mullins, 87 Wash. 403, 409, 151 P. 811 (1915); Denny v. Schwabacher, 54 Wash. 689, 692, 104 P. 137 (1909). The error is harmless, however. See In re Marriage of Shannon, 55 Wn. App. 137, 142, 777 P.2d 8 (1989) and discussion infra. The court found that the note/deed of trust was a gift to both Stephen and Theresa, characterized this gift as community property, and awarded each spouse a one-half interest therein. The distribution of the remaining property is not in dispute. ‹ Previous section Start of opinion Next section Continue reading › Studicata smart section • This header is not part of the opinion Kennedy, J. majority Legal Standards And Gift Challenge 1,034 words • ≈ 5 min 02 Summarize Simplify Copy source text Mark read Collapse Section summary The appellate standard is that trial courts have broad discretion in property division and will be reversed only for manifest abuse of that discretion. The trial court must first characterize property as community or separate but ultimately make a fair, just, and equitable division under RCW 26.09.080, considering factors like nature of property, duration of marriage, and each spouse's economic circumstances. Property acquired during marriage is presumptively community but that presumption may be rebutted by clear and convincing evidence. Stephen argues the promissory note was his separate inheritance and that the parents intended the gift to him alone. This summary is added by Studicata. Switch back to view the complete source text for this section. Simplified section Appellate review: reverse only for manifest abuse of discretion; court's reasoning must rest on tenable grounds. Characterization duty: court must label assets community or separate, considering source and acquisition date, but characterization is not dispositive if the distribution is equitable. RCW 26.09.080 lists factors for division: extent of community/separate property, marriage duration, and economic circumstances of each spouse among others. Presumption: property acquired during marriage is community; rebuttal requires clear and convincing evidence. Stephen's contention: the note was an inheritance to him alone (citing RCW 26.16.010) because his parents intended to transfer part of his inheritance to him. These simplified bullets are added by Studicata. Switch back to view the complete source text for this section. Discussion Stephen contends that the trial court erred in holding that (1) the promissory note/deed of trust was a gift to both Stephen and Theresa and (2) the white 1968 Ford Mustang was community property. In addition, he contends that the trial court abused its discretion under RCW 26.09.080 in allocating the property because the marriage was of very short duration and the property allocated was properly characterized as his separate property. A. Applicable Legal Standards. The trial court has broad discretion with respect to property division in a dissolution action and will be reversed only upon a showing of a manifest abuse of discretion. In re Marriage of Landry, 103 Wn.2d 807 , 809, 699 P.2d 214 (1985); In re Marriage of Kraft, 61 Wn. App. 45 , 50, 808 P.2d 1176 (1991), aff'd, 119 Wn.2d 438 , 832 P.2d 871 (1992); In re Marriage of Tower, 55 Wn. App. 697 , 700, 780 P.2d 863 (1989), review denied, 114 Wn.2d 1002 (1990). A manifest abuse of discretion is present if the court's discretion is exercised on untenable grounds, Tower, at 700; Kraft, at 50. In a dissolution action, all property, both community and separate, is before the trial court for distribution, Fried-lander v. Friedlander, 80 Wn.2d 293 , 305, 494 P.2d 208 [*329] (1972), and the court must dispose of all of the parties' property which is brought before it. In re Marriage of Soriano, 31 Wn. App. 432 , 437, 643 P.2d 450 (1982). RCW 26.09.080 sets forth relevant factors to be considered by the court, including but not limited to: (1) The nature and extent of the community property; (2) The nature and extent of the separate property; (3) The duration of the marriage; and (4) The economic circumstances of each spouse at the time the division of property is to become effective, including the desirability of awarding the family home or the right to live therein for reasonable periods to a spouse with whom the children reside the majority of the time. In considering the factors set forth in RCW 26.09.080 the courts have established a series of principles. To begin, the trial court has the duty to characterize the property as either community or separate. Blood v. Blood, 69 Wn.2d 680 , 682, 419 P.2d 1006 (1966); Baker v. Baker, 80 Wn.2d 736 , 745, 498 P.2d 315 (1972); In re Marriage of Hadley, 88 Wn.2d 649 , 656, 565 P.2d 790 (1977); In re Marriage of DeHollander, 53 Wn. App. 695 , 700, 770 P.2d 638 (1989). To accomplish this the court may consider the source of the property and the date it was acquired. DeRuwe v. DeRuwe, 72 Wn.2d 404 , 408, 433 P.2d 209 (1967); In re Marriage of Glorfield, 27 Wn. App. 358 , 361, 617 P.2d 1051 , review denied, 94 Wn.2d 1025 (1980). However, the status of the properly as community or separate is not controlling. Worthington v. Worthington, 73 Wn.2d 759 , 768, 440 P.2d 478 (1968). Rather, the trial court must ensure that the final division of the property is "fair, just and equitable under all the circumstances." In re Marriage of Hadley, 88 Wn.2d at 656 (quoting Baker, 80 Wn.2d at 745-46). See also Worthington, 73 Wn.2d at 768. The court may consider the health and ages of the parties, their prospects for future earnings, their education and employment histories, their necessities and financial abilities, their foreseeable future acquisitions and obligations, and whether the property to be divided should be attributed to the inheritance or efforts of one or both of the spouses. Friedlander, 80 [*330] Wn.2d at 305. See also In re Marriage of Kittleson, 21 Wn. App. 344 , 352, 585 P.2d 167 (1978), review denied, 92 Wn.2d 1009 (1979); Glorfield, 27 Wn. App. at 361 . Only in unusual circumstances would the trial court award the separate property of one spouse to the other. Merkel v. Merkel, 39 Wn.2d 102 , 115, 234 P.2d 857 (1951). Failure to properly characterize the property may be reversible error. Blood, at 682. However, mischaracterization of property is not grounds for setting aside a trial court's allocation of liabilities and assets, so long as the distribution is fair and equitable. In re Marriage of Brady, 50 Wn. App. 728 , 731, 750 P.2d 654 (1988); Worthington, 73 Wn.2d at 768-69;.Brossman v. Brossman, 32 Wn. App. 851 , 854, 650 P.2d 246 (1982), review denied, 98 Wn.2d 1017 (1983). Where there is mischaracterization, the trial court will be affirmed unless the reasoning of the court indicates (1) that the property division was significantly influenced by characterization and (2) that it is not clear that the court would have divided the property in the same way in the absence of the mischaracterization. In re Marriage of Shannon, 55 Wn. App. 137 , 142, 777 P.2d 8 (1989). Finally, although no single factor must be given greater weight than any other factor as a matter of law, In re Marriage of Konzen, 103 Wn.2d 470 , 478, 693 P.2d 97 , cert. denied, 473 U.S. 906 , 87 L. Ed. 2d 654 , 105 S. Ct. 3530 (1985), the economic circumstances of each spouse upon dissolution is of "paramount concern". DeRuwe v. DeRuwe, 72 Wn.2d at 408. B. Gift by Stephen's Parents of Promissory Note/Deed of Trust. Stephen asserts that the trial court abused its discretion in awarding a one-half interest in the assignment of the promissory note/deed of trust to Theresa. Stephen claims that this asset is his separate property. Specifically, he contends that his parents intended to transfer part of his inheritance to him. He points to Mildred Olivares' testimony that she and her husband barely knew Theresa, as she had only been married to Stephen for 2 months at the time that the [*331] gift was made, and they never intended to support Theresa for life through their assignment. Stephen points out that, if the property had been transferred by a will, the property would have been his separate property. RCW 26.16.010. ‹ Previous section Start of opinion Next section Continue reading › Studicata smart section • This header is not part of the opinion Kennedy, J. majority Donor Intent, Presumptions, And Martin Precedent 1,016 words • ≈ 5 min • Subscriber only 03 Unlock section Collapse This section of the court opinion is locked. Continue reading with an active Case Briefs+ subscription. Start your free trial or log in . ‹ Previous section Start of opinion Next section Continue reading › Studicata smart section • This header is not part of the opinion Kennedy, J. majority Final Application: Division And Car Gift Rule 994 words • ≈ 5 min • Subscriber only 04 Unlock section Collapse This section of the court opinion is locked. Continue reading with an active Case Briefs+ subscription. Start your free trial or log in . ‹ Previous section Start of opinion Next section Continue reading › Studicata smart section • This header is not part of the opinion Footnotes FOOTNOTES 107 words • ≈ 1 min 05 Summarize Simplify Copy source text Mark read Collapse Section summary These footnotes are referenced by the unlocked portions of the judicial opinion and remain in their original source order. This summary is added by Studicata. Switch back to view the complete source text for this section. Simplified section Each displayed note matches a footnote reference in unlocked source text. Additional notes remain available with the corresponding locked opinion text. These simplified bullets are added by Studicata. Switch back to view the complete source text for this section. FOOTNOTES [1] The parties have not briefed California law on this matter. Certainly the proposition sounds foreign to Washington lawyers and judges. [2] Since the trial court found the car to be a gift to Theresa, the court should have characterized the car as her separate property. See Scott v. Currie, 7 Wn.2d 301 , 307-08, 109 P.2d 526 (1941); Plath v. Mullins, 87 Wash. 403 , 409, 151 P. 811 (1915); Denny v. Schwabacher, 54 Wash. 689 , 692, 104 P. 137 (1909). The error is harmless, however. See In re Marriage of Shannon, 55 Wn. App. 137 , 142, 777 P.2d 8 (1989) and discussion infra. ‹ Previous section Start of opinion Next section Continue reading › › Integrated tools Study Controls Find in opinion Search the unlocked verbatim source text. Reader settings Text size A− A+ Line spacing Tight Normal Relaxed Reading mode Light Dark Summarize all Simplify all Collapse all Enter focus mode Opinion filter Temporarily isolate one part of the Court’s opinions. All Majority Concurrence Dissent Keyboard shortcuts ← → Previous or next section S Summarize current section B Simplify bullet current section M Mark current section read F Enter or exit focus mode 1-Minute Brief Case Snapshot Expand All 1 Quick Facts What happened Stephen and Theresa Olivares married in 1988 and separated in 1990. During the marriage, Stephen’s parents assigned a valuable promissory note and deed of trust to both spouses, while Stephen bought a Mustang with separate credit and titled it to Theresa. Full Facts > 2 Quick Issue Legal question Whether the note was a community gift, whether the Mustang was gifted to Theresa, and whether the property division was fair despite the marriage’s short duration. Full Issue > 3 Quick Holding Court’s answer The note was community property, the Mustang was gifted to Theresa, and the equal division of the note was equitable. The court affirmed, treating the Mustang’s incorrect community-property label as harmless. Full Holding > 4 Quick Rule Key takeaway Gifts to both spouses are generally community property absent clear contrary intent, while separately financed property titled to the other spouse presumptively becomes that spouse’s gift. Property division must be fair and equitable. Full Rule > 5 Why this case matters Exam focus Washington courts distinguish property characterization from final distribution. Even when a trial court mislabels an asset, the award may stand if the overall division remains fair and the label did not affect the result. Full Why this case matters > Exam Core An unstated hope that spouses stay married cannot undo a completed gift to both; courts may still divide property fairly based on need and resources. In re the Marriage of Olivares , 69 Wash. App. 324 (1993). Family Law Community Property Principles Equitable Distribution of Marital Property Marital vs Separate Property Characterization The Core Main Case Brief Facts Go Deep Simplify In In re the Marriage of Olivares, Stephen and Theresa married on December 22, 1988, and separated on August 1, 1990, after a marriage funded largely by Stephen’s assets, parental gifts, and loans. In early 1989, Stephen’s parents assigned a promissory note and deed of trust worth about $235,000 to Stephen and Theresa through a California escrow company. During the marriage, Stephen also bought a classic 1968 Ford Mustang using separate credit and titled it in Theresa’s name. After the trial court dissolved the marriage, it treated both the note and the Mustang as community property, awarded Theresa the Mustang, and divided the note equally. Stephen appealed the characterization and distribution of those assets. Simplify is available with Studicata Case Briefs+. Start Case Briefs+ trial Go Deep is available with Studicata Case Briefs+. Start Case Briefs+ trial Want deeper facts or a simpler explanation? Try both study modes. Simplify any section Turn on Simplify to read the same section in clear, plain language. It helps you understand the key point faster—without getting lost in complicated wording. Go deeper on the facts Preparing for class or a cold call? Turn on Go Deep for a fuller, step-by-step breakdown of what happened, so you can feel ready to discuss the case. Try both with a quick demo Issue Simplify The main issues were whether Stephen’s parents gave the promissory note and deed of trust to both spouses, whether Stephen gave Theresa the Mustang, and whether the property division was fair despite the marriage’s short duration. Simplify is available with Studicata Case Briefs+. Start Case Briefs+ trial Holding — Kennedy, J. Simplify The court held that the note and deed of trust were a community gift to both spouses, that the Mustang was gifted to Theresa despite the trial court’s harmless mischaracterization, and that the equal division was equitable; it affirmed the judgment. Simplify is available with Studicata Case Briefs+. Start Case Briefs+ trial Reasoning Simplify The court began with Washington’s rules that property acquired during marriage is presumed community and that gifts to both spouses are generally community property. Stephen did not prove a clear contemporaneous intent to give the note only to him. The assignment named both spouses, the parents knew Theresa would benefit, and no one told her that the gift depended on the marriage continuing. An executed gift becomes effective upon delivery, so an unstated hope that the couple would remain married could not undo it. For the Mustang, Stephen used separate credit but titled the car to Theresa, creating a rebuttable presumption of a gift. The trial court was entitled to believe Theresa’s testimony. Although the car should have been called Theresa’s separate property, the error was harmless because she received it. Finally, the court upheld the equal note division because Stephen had substantial assets while Theresa had limited resources and community labor had improved the Arlington home. Simplify is available with Studicata Case Briefs+. Start Case Briefs+ trial Key Rule Simplify Property acquired during marriage is presumed community unless clear and convincing evidence proves a separate gift; a separately financed asset titled to the other spouse is presumptively gifted to that spouse; and property division must be fair and equitable under all circumstances. Simplify is available with Studicata Case Briefs+. Start Case Briefs+ trial Deeper Analysis In-Depth Discussion The Governing Framework In-depth discussion explains the court’s analysis, the legal standards it applied, and the exam-relevant implications of the decision. This block is available only to active Case Briefs+ subscribers. Start your free trial or log in . The Parents’ Gift In-depth discussion explains the court’s analysis, the legal standards it applied, and the exam-relevant implications of the decision. This block is available only to active Case Briefs+ subscribers. Start your free trial or log in . The Unstated Condition In-depth discussion explains the court’s analysis, the legal standards it applied, and the exam-relevant implications of the decision. This block is available only to active Case Briefs+ subscribers. Start your free trial or log in . The Mustang and Harmless Error In-depth discussion explains the court’s analysis, the legal standards it applied, and the exam-relevant implications of the decision. This block is available only to active Case Briefs+ subscribers. Start your free trial or log in . Why the Division Stood In-depth discussion explains the court’s analysis, the legal standards it applied, and the exam-relevant implications of the decision. This block is available only to active Case Briefs+ subscribers. Start your free trial or log in . Class Prep Cold Calls Being called on in law school can feel intimidating—but don’t worry, we’ve got you covered. Reviewing these common questions ahead of time will help you feel prepared and confident when class starts. Expand All What property did Stephen challenge on appeal? Locked Upgrade to reveal this cold-call answer. When did Stephen and Theresa marry and separate? Locked Upgrade to reveal this cold-call answer. Why did Stephen claim the note was his separate property? Locked Upgrade to reveal this cold-call answer. What evidence supported treating the note as a gift to both spouses? Locked Upgrade to reveal this cold-call answer. What presumption applies to property acquired during marriage? Locked Upgrade to reveal this cold-call answer. What evidence could have made the note Stephen’s separate property? Locked Upgrade to reveal this cold-call answer. Why did the court reject the alleged condition that the spouses remain married? Locked Upgrade to reveal this cold-call answer. What happens to an executed gift after delivery? Locked Upgrade to reveal this cold-call answer. Why did the Mustang create a presumption of a gift to Theresa? Locked Upgrade to reveal this cold-call answer. How did the trial court resolve the conflicting testimony about the Mustang? Locked Upgrade to reveal this cold-call answer. Why did the appellate court defer to the trial court’s credibility decision? Locked Upgrade to reveal this cold-call answer. What was technically wrong with the Mustang’s characterization? Locked Upgrade to reveal this cold-call answer. Why was the Mustang’s mischaracterization harmless? Locked Upgrade to reveal this cold-call answer. Why did the court uphold the equal division of the note? Locked Upgrade to reveal this cold-call answer. Explore More Explore More Law School Case Briefs Compare In re the Marriage of Olivares with other related cases. In re Salvini's Estate Supreme Court of Washington: A gift to both a husband and wife during marriage is considered community property, not separate property, under community property laws. Connell v. Francisco Supreme Court of Washington: Property acquired during a meretricious relationship is presumed to be owned by both parties and is subject to equitable distribution, while property owned prior to the relationship is not subject to division. In re Marriage of Frick Court of Appeal of California: Community property interests in separate property acquired before marriage are subject to apportionment based on the ratio of community contributions to the total property value, and proper tracing and documentation are required to establish separate property claims. Hourigan v. Hourigan Court of Civil Appeals of Texas: A trial court has broad discretion in dividing community property in divorce proceedings, and its decision should be corrected on appeal only if there is an abuse of discretion, taking into account various factors including fault, income disparity, and child support obligations. Wolfe v. Wolfe Court of Appeals of Oregon: In a long-term marriage, equitable distribution requires considering the social and financial objectives of the dissolution and the extent to which separate property has been integrated into the marital partnership. From class prep to bar prep, we’ve got you. Get Studicata+ for full case brief access, video lectures, outlines, and study tools—or compare all three plans to find the support that fits you best. Get Studicata+ Compare all plans Table of Contents Simplify all PDF Case Snapshot Main Case Brief Facts Issue Holding — Kennedy, J. Reasoning Key Rule In-Depth Discussion The Governing Framework The Parents’ Gift The Unstated Condition The Mustang and Harmless Error Why the Division Stood Cold Calls Related Cases Table of Contents Jump Simplify all PDF Case Snapshot Main Case Brief Facts Issue Holding — Kennedy, J. Reasoning Key Rule In-Depth Discussion The Governing Framework The Parents’ Gift The Unstated Condition The Mustang and Harmless Error Why the Division Stood Cold Calls Related Cases Interactive feature demo Hamer v. Sidway Demo Use the toggle controls below to compare the original Facts section with the Simplify and Go Deep versions. Facts Go Deep Simplify In Hamer v. Sidway, William E. Story promised his nephew, William E. Story, 2d, that if he refrained from drinking liquor, using tobacco, swearing, and playing cards or billiards for money until he turned 21, he would be paid $5,000. The nephew complied with these terms. However, when the nephew reached the age of 21 and requested the payment, the uncle suggested holding onto the money until the nephew was more mature. The uncle later died, and the executor of his estate, Sidway, refused to make the payment, arguing that the contract lacked consideration. The trial court ruled in favor of the nephew, recognizing that he had fulfilled his part of the agreement. This decision was affirmed by the appellate court, and Sidway appealed to the Court of Appeals of New York. An uncle promised his nephew $5,000 if the nephew gave up certain habits until age 21. The nephew stopped drinking, using tobacco, swearing, and gambling for money until he turned 21. When the nephew asked for the money at 21, the uncle wanted to wait until he was older. The uncle died and the estate executor refused to pay the $5,000. The executor argued there was no valid consideration for the promise. Lower courts ruled for the nephew because he kept his promise, and the executor appealed. William E. Story (the uncle) and William E. Story, 2d (the nephew) were related as uncle and nephew. On March 20, 1869, the uncle promised to pay the nephew $5,000 when the nephew turned 21 if, until that time, the nephew did not drink liquor, use tobacco, swear, or play cards or billiards for money. The nephew accepted the uncle's March 20, 1869 promise and agreed to follow its conditions. The trial court found that the nephew fully performed everything required of him under the March 20, 1869 agreement. Before the agreement, the nephew occasionally drank liquor and used tobacco, and he had a legal right to do so. In reliance on his uncle's promise, the nephew gave up his legal right to drink liquor, use tobacco, and participate in the other specified activities for the agreed period. The nephew turned 21 on January 31, 1875. On January 31, 1875, the nephew wrote to his uncle stating that he had turned 21 that day, believed the uncle owed him $5,000 under the agreement, and had followed the contract “to the letter in every sense of the word.” A few days later, on February 6, 1875, the uncle replied by letter and acknowledged receiving the nephew's January 31, 1875 letter. In his February 6, 1875 letter, the uncle stated that he had no doubt the nephew had kept his promise and that the nephew “shall have $5,000 as I promised you.” In the same letter, the uncle stated that he had the money in the bank on the day the nephew turned 21, that he intended the money for the nephew, and that the nephew “shall have the money certain.” The uncle also stated in the February 6, 1875 letter that he would not allow the nephew to control the money until he believed the nephew was capable of taking care of it and that the nephew could consider the money to be earning interest. The trial court found that the nephew received the February 6, 1875 letter and then agreed to allow the money to remain with the uncle under the terms and conditions stated in that letter. On March 1, 1877, with the uncle's knowledge and consent, the nephew sold, transferred, and assigned all of his rights and interests in the $5,000 to his wife, Libbie H. Story. After March 1, 1877, Libbie H. Story sold, transferred, and assigned the rights and interests she had received from the nephew to Hamer, the plaintiff in this action. In the February 6, 1875 letter, the uncle did not use the word “trust” or state that the money had been deposited in the nephew's name or placed in trust for him. However, the uncle used language stating that he had “set apart” the money in the bank for the nephew and would not “interfere” with it until the nephew was capable of taking care of it. The trial court found that, when read in light of the surrounding circumstances, the February 6, 1875 letter showed that the uncle intended to keep the money in a particular way and that the nephew agreed to that arrangement. The trial court found that, on January 31, 1875, the uncle owed the nephew $5,000 under the March 20, 1869 agreement. The defendant raised the Statute of Limitations as a defense to any claim based solely on the debt created by the original contract. The trial court made findings about the uncle's letter and the nephew's agreement to its terms that were relevant to deciding whether their later relationship was that of debtor and creditor or trustee and beneficiary. According to the trial court's description, the General Term opinion appeared to conclude that the trust was completed during the uncle's lifetime when payment was made to the nephew. At Special Term, the trial court entered judgment in favor of the plaintiff, and the opinion discusses affirming that judgment. The intermediate appellate court's order was appealed, and the court issuing this opinion reversed that order. The case was argued on February 24, 1891, and decided on April 14, 1891. Law school & bar prep trusted by 100,000+ students. Explore Case Briefs Videos Outlines Essay Exams Full Bar Review Pricing 4M+ Case Summaries Account Log in Sign up Skool (Legacy) Request a Case Brief Legal & Support Testimonials Terms of Use Privacy Policy Help Center © 2025 Studicata LLC NCBE®, MBE®, MEE®, MPT® and UBE® are trademarks of the National Conference of Bar Examiners. \ No newline at end of file diff --git a/.research/olivares_vlex.txt b/.research/olivares_vlex.txt new file mode 100644 index 0000000..5e3f5bf --- /dev/null +++ b/.research/olivares_vlex.txt @@ -0,0 +1 @@ +In re the Marriage of Olivares (In re the Marriage of Olivares, 69 Wash. App. 324 (Wash. App. 1993)) - vLex United States VINCENT AI Legal Research Coverage DOCKET ALARM Login Sign Up Home Case Law In re the Marriage of Olivares Document Cited authorities (18) Cited in Precedent Map Related Court Washington Court of Appeals Citation In re the Marriage of Olivares, 69 Wash. App. 324 (Wash. App. 1993) Decision Date 12 April 1993 Docket Number No. 28758-3-I,28758-3-I Parties In the Matter of the Marriage of Stephen R. Olivares, Appellant, and Theresa R. Olivares, Respondent. 69 Wash. App. 324 In re the Marriage of Olivares [ No. 28758-3 -I. Washington Court of Appeals April 12, 1993 .] Philip A. Talmadge , Celeste A. McDonell , and Talmadge & Cutler, P.S.; Thomas D. Bigsby and Bigsby & Willson , for appellant . Jerome L. Jager and Donna McNamara , for respondent . Kennedy , J. This appeal arises out of the dissolution of the marriage of appellant Stephen R. Olivares and respon*326 dent Theresa R. Olivares . Stephen appeals the trial court 's characterization and distribution of a classic white Ford Mustang automobile and a promissory note/deed of trust. We affirm. Facts Stephen and Theresa Olivares met when Theresa responded to a newspaper ad placed by Stephen in the Little Nickel Want Ads. Theresa was in her late forties and Stephen was in his early fifties. When the parties met, Theresa's second divorce was not yet final. The couple dated for about 6 months and married on December 22, 1988 , in the state of Arizona . This was the third marriage for each party and both parties have adult children from prior marriages. At the time of the marriage, Stephen, who is a carpenter by trade, had substantial property. His assets included a rental house in Arlington, Washington, a house under construction in Arlington and a car collection. Theresa's assets at the time of marriage were limited to an old car, a $1,000 certificate of deposit, and $3,000 in cash. From the time of their marriage in December 1988 , until their separation on August 1, 1990 , neither party was employed. The majority of the marriage was spent traveling outside of the United States on an extended honeymoon and on vacations to the southwestern United States, Hawaii and Mexico, paid for by Stephen's parents. When the couple was not traveling they worked together on the Arlington house, which was substantially completed during the marriage. During their marriage, the Olivares lived off the proceeds of the sale of Stephen's rental house and on gifts and loans from-his parents. The couple also borrowed money from Theresa's children. In early 1989 , in an attempt to simplify their affairs, Stephen's elderly parents transferred three trust deeds, one to each of their sons and their sons' wives. Stephen and Theresa were assigned the proceeds of a promissory note/ deed of trust worth about $235,000. The note at issue here pays $2,000 per month for 27 years. The assignment was accomplished through an escrow company in California, without the assistance of an attorney. Initially, the parents were making the assignment to Stephen. However, the escrow agent added Theresa's name to the transfer documents, explaining to Stephen and his parents that it was "required by law" to include both the husband and wife as joint tenants. 1 Mildred Olivares , Stephen's mother , testified that the purpose of the gifts was to give her three sons and their children part of their inheritance. She also stated, however, that she knew that Theresa's name was included on the assignment and that Theresa would benefit from the gift, as it was expected that Theresa and Stephen would five on the proceeds. Mildred also indicated that she had not considered that her son and Theresa might not stay married and that she had never told Theresa that the gift to her was conditioned upon her and Stephen remaining married. The payments were set up to go into an escrow account, with both Stephen's and Theresa's Social Security numbers on the account. Prior to the couple's marital difficulties, no one ever indicated to Theresa that the assignment of the contract was not for her benefit. Theresa testified that Stephen's parents were happy with her and happy that Stephen was finally breaking out of his depression. She testified that she was told she was to be included in the gift and that she told Stephen's parents she was very appreciative and that it was a wonderful present. During the marriage the Olivares sold Theresa's old car, a 1983 Dodge. Stephen purchased a classic white 1968 Ford Mustang with a loan based on his separate credit and placed the title in Theresa's name. Stephen contends that he placed the car's title in his wife's name so that he could sell it later that year. He testified that he had already sold as many vehicles that year as he was allowed by law without obtaining a dealer's license. Theresa asserted that the car's title was in her name because it was a gift to her. The trial court found the marriage to be irretrievably broken and granted dissolution of the marriage. The trial court found the 1968 classic white Ford Mustang to be a gift from Stephen to his wife, characterized it as community property and awarded it to Theresa.2 The court found that the note/deed of trust was a gift to both Stephen and Theresa, characterized this gift as community property, and awarded each spouse a one-half interest therein. The distribution of the remaining property is not in dispute. Discussion Stephen contends that the trial court erred in holding that (1) the promissory note/deed of trust was a gift to both Stephen and Theresa and (2) the white 1968 Ford Mustang was community property. In addition, he contends that the trial court abused its discretion under RCW 26.09.080 in allocating the property because the marriage was of very short duration and the property allocated was properly characterized as his separate property. A. Applicable Legal Standards. The trial court has broad discretion with respect to property division in a dissolution action and will be reversed only upon a showing of a manifest abuse of discretion. In re Marriage of Landry , 103 Wn.2d 807 , 809 , 699 P.2d 214 ( 1985 ) ; In re Marriage of Kraft , 61 Wn. App. 45 , 50 , 808 P.2d 1176 ( 1991 ) , aff'd , 119 Wn.2d 438 , 832 P.2d 871 ( 1992 ) ; In re Marriage of Tower , 55 Wn. App. 697 , 700 , 780 P.2d 863 ( 1989 ) , review denied , 114 Wn.2d 1002 ( 1990 ) . A manifest abuse of discretion is present if the court 's discretion is exercised on untenable grounds, Tower , at 700 ; Kraft , at 50 . In a dissolution action, all property, both community and separate, is before the trial court for distribution, Fried-lander v. Friedlander , 80 Wn.2d 293 , 305 , 494 P.2d 208 *329 ( 1972 ) , and the court must dispose of all of the parties ' property which is brought before it. In re Marriage of Soriano , 31 Wn. App. 432 , 437 , 643 P.2d 450 ( 1982 ) . RCW 26.09.080 sets forth relevant factors to be considered by the court , including but not limited to: (1) The nature and extent of the community property; (2) The nature and extent of the separate property; (3) The duration of the marriage; and (4) The economic circumstances of each spouse at the time the division of property is to become effective, including the desirability of awarding the family home or the right to live therein for reasonable periods to a spouse with whom the children reside the majority of the time. In considering the factors set forth in RCW 26.09.080 the courts have established a series of principles. To begin, the trial court has the duty to characterize the property as either community or separate. Blood v. Blood , 69 Wn.2d 680 , 682 , 419 P.2d 1006 ( 1966 ) ; Baker v. Baker , 80 Wn.2d 736 , 745 , 498 P.2d 315 ( 1972 ) ; In re Marriage of Hadley , 88 Wn.2d 649 , 656 , 565 P.2d 790 ( 1977 ) ; In re Marriage of DeHollander , 53 Wn. App. 695 , 700 , 770 P.2d 638 ( 1989 ) . To accomplish this the court may consider the source of the property and the date it was acquired. DeRuwe v. DeRuwe , 72 Wn.2d 404 , 408 , 433 P.2d 209 ( 1967 ) ; In re Marriage of Glorfield , 27 Wn. App. 358 , 361 , 617 P.2d 1051 , review denied , 94 Wn.2d 1025 ( 1980 ) . However, the status of the properly as community or separate is not controlling. Worthington v. Worthington , 73 Wn.2d 759 , 768 , 440 P.2d 478 ( 1968 ) . Rather, the trial court must ensure that the final division of the property is "fair, just and equitable under all the circumstances." In re Marriage of Hadley , 88 Wn.2d at 656 ( quoting Baker , 80 Wn.2d at 745-46 ) . See also Worthington , 73 Wn.2d at 768 . The court may consider the health and ages of the parties , their prospects for future earnings, their education and employment histories, their necessities and financial abilities, their foreseeable future acquisitions and obligations, and whether the property to be divided should be attributed to the inheritance or efforts of one or both of the spouses. Friedlander, 80 * 330 Wn.2d at 305 . See also In re Marriage of Kittleson , 21 Wn. App. 344 , 352 , 585 P.2d 167 ( 1978 ) , review denied , 92 Wn.2d 1009 ( 1979 ) ; Glorfield , 27 Wn. App. at 361 . Only in unusual circumstances would the trial court award the separate property of one spouse to the other. Merkel v. Merkel , 39 Wn.2d 102 , 115 , 234 P.2d 857 ( 1951 ) . Failure to properly characterize the property may be reversible error. Blood , at 682 . However, mischaracterization of property is not grounds for setting aside a trial court 's allocation of liabilities and assets, so long as the distribution is fair and equitable. In re Marriage of Brady , 50 Wn. App. 728 , 731 , 750 P.2d 654 ( 1988 ) ; Worthington , 73 Wn.2d at 768-69 ; . Brossman v. Brossman , 32 Wn. App. 851 , 854 , 650 P.2d 246 ( 1982 ) , review denied , 98 Wn.2d 1017 ( 1983 ) . Where there is mischaracterization, the trial court will be affirmed unless the reasoning of the court indicates (1) that the property division was significantly influenced by characterization and (2) that it is not clear that the court would have divided the property in the same way in the absence of the mischaracterization. In re Marriage of Shannon , 55 Wn. App. 137 , 142 , 777 P.2d 8 ( 1989 ) . Finally, although no single factor must be given greater weight than any other factor as a matter of law, In re Marriage of Konzen , 103 Wn.2d 470 , 478 , 693 P.2d 97 , cert. denied , 473 U.S. 906 , 87 L. Ed. 2d 654 , 105 S. Ct. 3530 ( 1985 ) , the economic circumstances of each spouse upon dissolution is of "paramount concern" . DeRuwe v. DeRuwe , 72 Wn.2d at 408 . B. Gift by Stephen's Parents of Promissory Note/Deed of Trust. Stephen ... 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Washington Supreme Court, 2000 +

In Re Marriage of Pennington

In Re Marriage of Pennington
Washington Supreme Court · Decided December 21, 2000 · Johnson
14 P.3d 764 +(Pacific Reporter, Third Series)

In Re Marriage of Pennington

Opinion

14 P.3d 764 (2000)
142 Wash.2d 592

In re the MARRIAGE OF Sammi PENNINGTON, a/k/a Evelyn Lorraine Van Pevenage, Petitioner, and
Clark Melvyn Pennington, Respondent.
In re the Meretricious Relationship of Diana J. Chesterfield, Respondent, and
James E. Nash, Petitioner.

No. 67900-2.

Supreme Court of Washington, En Banc.

Argued February 15, 2000.
Decided December 21, 2000.

*766 Edwards, Sieh, Smith & Goodfriend, Catherine Wright Smith, Seattle, Charles Wiggins, Kenneth Masters, Bainbridge Island, Troup, Christnacht, Michael Joseph McKasy, Tacoma, for Petitioners.

Smith, Alling, Lane, Edward Marshall Lane, Tacoma, Mary Louise Gaudio, Daniel Leward Modeen, Bellevue, for Respondents.

*765 JOHNSON, J.

In these consolidated cases, we must determine whether the legal requirements to establish a meretricious relationship were satisfied so as to allow for equitable relief under our holdings in Connell v. Francisco, 127 Wash.2d 339, 898 P.2d 831 (1995) and In re Marriage of Lindsey, 101 Wash.2d 299, 678 P.2d 328 (1984). We hold the facts of these cases do not support concluding the existence of stable, cohabiting relationships for either of the parties. Furthermore, we hold neither party made a sufficient showing to justify recovery under other equitable theories. We affirm the Court of Appeals in Pennington v. Pennington, 93 Wash.App. 913, 971 P.2d 98 (1999), reverse the Court of Appeals in Chesterfield v. Nash, 96 Wash. App. 103, 978 P.2d 551 (1999), and remand both cases to the trial courts.[1]

FACTS

Pennington v. Pennington

Respondent Clark Pennington met petitioner Evelyn Van Pevenage (aka Sammi Pennington)[2] in March 1983. At this time, both Pennington and Van Pevenage were married to other people. Van Pevenage's divorce was finalized in December 1983. Pennington separated from his wife in October *767 1983, but remained married until 1990. Pennington and Van Pevenage began dating each other and, in August 1985, moved in together at Pennington's residence in Kapowsin, Washington. The parties also commenced a sexual relationship.

The Kapowsin residence was an airplane hangar with an unfinished apartment upstairs. Clark Pennington and his wife, Jane Pennington, paid the utilities and mortgage payments. Van Pevenage paid for groceries as well as some home furnishings; her income derived from her work as a bartender and lounge manager at various restaurants. Pennington's income derived from his proprietorship of Exacto, Inc., a corporation manufacturing aircraft and machine parts.

Van Pevenage testified at trial that towards the end of 1986 Pennington proposed marriage to her and gave her an engagement ring. Pennington denied ever proposing marriage and characterized the gift as a "cocktail ring."

In 1987, Pennington purchased a lot in Yelm, Washington. He did so by assuming the underlying real estate contract on the land and agreeing to make cash payments of $700 per month. Pennington made the contract payments from his wages and from rent paid to him by Exacto, Inc. The deed to the property conveyed the land to "Clark M. Pennington, a married man dealing with his separate estate." Ex. 41. Pennington's wife, Jane Pennington, quitclaimed her interest in the Yelm property to him in 1988. Pennington then took out a loan solely in his name to pay off the real estate contract and finance construction of a hangar and a new home on the property. Van Pevenage testified she participated in the interior design of the home, although the housing contractor testified he did not take instructions from her. Pennington and Van Pevenage moved into the Yelm home in December 1988. The home loan payments were made from Pennington's Exacto, Inc. wages and from the sale of the Kapowsin residence.

During the course of their relationship, Pennington provided vehicles for Van Pevenage to drive and placed her on his automobile insurance policy.[3] He also named Van Pevenage as the beneficiary of a $50,000 life insurance policy. Van Pevenage acquired credit cards in the name of "Sammi Pennington," and registered Clark and herself in the Yelm telephone book as "Pennington Clark & Sammi." Pennington and Van Pevenage also held joint checking accounts. Pennington denied authorizing Van Pevenage to use his last name for either the telephone book or the credit cards, and testified he had no knowledge she had done so until after the relationship terminated.

Van Pevenage lived with Pennington in the Yelm home continuously until 1991. In April 1991, she moved into an apartment, but returned to the Yelm residence shortly thereafter.[4] Several months later, Pennington suffered a stroke and was hospitalized. Van Pevenage temporarily quit her job to help Pennington around the house, but Pennington returned to work only one week after his release from the hospital. After the stroke, Exacto, Inc. provided Van Pevenage with medical insurance coverage and paid her a salary of approximately $1,000 per month, although Van Pevenage did not have an "active role" in the corporation's business. The salary continued intermittently until 1996. After his stroke, Pennington also gave Van Pevenage signing privileges on the corporate account.

Van Pevenage moved out of the Yelm residence from March 1993 until October 1994. In May 1994, Van Pevenage commenced a sexual relationship with another man, whom she resided with in September of that year. Pennington dated another woman during this time period. Van Pevenage eventually returned to the Yelm residence for one more year, before leaving again in October 1995. Her relationship with Pennington was not sexual during this last year.

In 1996, Van Pevenage filed a complaint in superior court for dissolution of a meretricious *768 relationship between Pennington and herself. The trial court concluded such a relationship did exist, determined that certain property acquired during the relationship should be treated as community property for the purpose of making a just and equitable division of such property, and awarded Van Pevenage a total judgment of $214,200, less amounts already received. Pennington appealed, and the Court of Appeals reversed. Pennington, 93 Wash.App. 913, 971 P.2d 98. The Court of Appeals held no meretricious relationship existed between Pennington and Van Pevenage, primarily because "during most of the period that the trial court terms `meretricious,' the parties were not free to marry legally, did not intend to marry, or punctuated their living together with a third party relationship." Pennington, 93 Wash.App. at 919, 971 P.2d 98. Van Pevenage filed a petition for review with this court, which we granted.

Chesterfield v. Nash

Petitioner James Nash and respondent Diana Chesterfield began a casual dating relationship in August 1986. A few months later the relationship became sexually intimate. Chesterfield worked as a salesperson at Nordstrom, and Nash operated a dental practice he had purchased in 1985. Chesterfield was married, although separated, at the time she began dating Nash. Chesterfield filed for divorce in November 1987. The parties dated from 1986 until 1989, although Nash dated other women during this time period. In July 1989, Nash and Chesterfield moved into a home purchased the previous year by Chesterfield.

While living together, Nash and Chesterfield opened a joint checking account to which they both contributed funds. The account was opened for the purpose of funding living expenses; it was used to pay the mortgage and taxes on the house, as well as groceries, utility bills, and other miscellaneous matters. Contributions to the account were initially equal, but over time Nash contributed more than Chesterfield.[5] Nash testified he also paid nearly all expenses for their numerous vacations, and a disproportionate amount of their dining out expenses. Chesterfield had a profit sharing plan at Nordstrom, but refused to invest those funds in Nash's dental practice unless the two were married. Chesterfield also testified she would not invest in a house with Nash until they were married. Overall, Chesterfield's spending patterns did not change during the period of cohabitation, although she received promotions and pay increases at Nordstrom.

Nash and Chesterfield periodically assisted each other professionally. Nash aided Chesterfield with work-related travel logs and offered her the use of the computer at his dental practice. Chesterfield aided Nash as a temporary dental assistant, helped process accounts payable for several months, and performed word processing tasks. Nash offered to compensate Chesterfield for her help, but she refused.

Nash and Chesterfield ceased living together in October 1993. Chesterfield closed the joint account and made a mortgage payment with the remaining funds. In 1994, Nash and Chesterfield briefly reconciled and began dating again, although they did not resume living together. They discussed marriage and Nash purchased a diamond for Chesterfield, but in November 1995 they permanently ended their relationship.

Chesterfield filed a petition for disposition of property rights of a meretricious relationship in superior court. The trial court found Nash and Chesterfield had a meretricious relationship, certain property acquired during that relationship should be treated as community property for the purposes of making a just and equitable division of that property, and a 60/40 percent ratio in favor of Nash was the appropriate basis of division. The trial court entered a judgment of $75,594 plus costs, in favor of Chesterfield. Included in the court's valuation and division of property was a $40,000 increase in the goodwill of Nash's dental practice.

*769 Nash timely appealed, and the Court of Appeals affirmed. Chesterfield, 96 Wash. App. at 117, 978 P.2d 551. The Court of Appeals concluded Nash and Chesterfield had a meretricious relationship primarily because they "lived together continuously in a stable, mutually-supportive relationship for longer than four years, functioning as one would expect a married couple to function with regard to work." Chesterfield, 96 Wash. App. at 109, 978 P.2d 551. Although the Court of Appeals conceded "Nash's name did not appear on the title of the house in which they lived, and that Chesterfield and Nash did not hold themselves out as being married or commingle their resources for purposes other than living expenses," it found this insignificant. Chesterfield, 96 Wash.App. at 109, 978 P.2d 551. The Court of Appeals held the trial court properly divided the goodwill of the dental practice. Chesterfield, 96 Wash.App. at 111-17, 978 P.2d 551. Nash petitioned this court for review, which we granted and consolidated with Pennington.

ANALYSIS

Our Legislature requires a solemnized "civil contract" in order for a marriage to be valid. RCW 26.04.010(1); see also RCW 26.04.050, .120, .130; Meton v. Indus. Ins. Dep't, 104 Wash. 652, 655, 177 P. 696 (1919); In re Estate of McLaughlin, 4 Wash. 570, 588-89, 30 P. 651 (1892); Roe v. Ludtke Trucking, Inc., 46 Wash.App. 816, 819, 732 P.2d 1021 (1987). Common-law marriage is not recognized under Washington law. Peffley-Warner v. Bowen, 113 Wash.2d 243, 249, 778 P.2d 1022 (1989); In re Estate of Gallagher, 35 Wash.2d 512, 514-15, 213 P.2d 621 (1950).[6] Wholly unrelated to either kind of marriage, courts have recognized the existence of meretricious relationships, which this court has determined to be stable, cohabiting relationships. See Connell, 127 Wash.2d at 346, 898 P.2d 831.

For nearly a century, Washington law presumed all property acquired by unmarried cohabitants belonged to the holder of the legal title. See, e.g., Latham v. Hennessey, 87 Wash.2d 550, 552-53, 554 P.2d 1057 (1976); Creasman v. Boyle, 31 Wash.2d 345, 358, 196 P.2d 835 (1948); Engstrom v. Peterson, 107 Wash. 523, 530, 182 P. 623 (1919); Stans v. Baitey, 9 Wash. 115, 119, 37 P. 316 (1894). However, even when this presumption applied, courts recognized a variety of exceptions to this presumption. See Latham, 87 Wash.2d at 553-54, 554 P.2d 1057. Among these exceptions were: (1) tracing source of funds, West v. Knowles, 50 Wash.2d 311, 313, 311 P.2d 689 (1957); (2) implied partnership/joint venture, In re Estate of Thornton, 81 Wash.2d 72, 78-81, 499 P.2d 864 (1972); (3) resulting trusts, Walberg v. Mattson, 38 Wash.2d 808, 812-14, 232 P.2d 827 (1951); (4) constructive trusts, Humphries v. Riveland, 67 Wash.2d 376, 389-90, 407 P.2d 967 (1965); (5) tenancy in common, Shull v. Shepherd, 63 Wash.2d 503, 506, 387 P.2d 767 (1963); and (6) contract theory, Dahlgren v. Blomeen, 49 Wash.2d 47, 50-52, 298 P.2d 479 (1956).

In 1984, this court discarded this presumption. Lindsey, 101 Wash.2d 299, 678 P.2d 328. Lindsey involved a couple who commenced an intimate relationship in 1974, legally married in 1976, and divorced in 1982. Lindsey, 101 Wash.2d at 300, 678 P.2d 328. The court declined to presume that property acquired before the legal marriage belonged to the holder of title, instead holding "that courts must `examine the [meretricious] relationship and the property accumulations and make a just and equitable disposition of the property.'" Lindsey, 101 Wash.2d at 304, 678 P.2d 328 (quoting Latham, 87 Wash.2d at 554, 554 P.2d 1057). As a meretricious relationship was conceded by both parties, this court remanded for a determination of how insurance proceeds from a building the couple helped construct should be divided. Lindsey, 101 Wash.2d at 306-07, 678 P.2d 328.

This court again considered the issue of meretricious relationships in Connell, 127 Wash.2d 339, 898 P.2d 831. Connell, like *770 Lindsey, involved an uncontested meretricious relationship. Connell, 127 Wash.2d at 346, 898 P.2d 831. Connell and Francisco had an intimate relationship and lived together from 1983 until 1990. In 1986, they moved to Whidbey Island, Washington, where Connell managed a bed and breakfast purchased by Francisco's corporation. Connell, 127 Wash.2d at 343, 898 P.2d 831. We characterized meretricious as a "stable, marital-like relationship where both parties cohabit with knowledge that a lawful marriage between them does not exist." Connell, 127 Wash.2d at 346, 898 P.2d 831 (citing Lindsey, 101 Wash.2d at 304, 678 P.2d 328; Harry M. Cross, The Community Property Law in Washington (Revised 1985), 61 Wash.L.Rev. 13, 23 (1986)). The use of the term "marital-like" is a mere analogy because defining meretricious relationships as related to marriage would create a de facto common-law marriage, which this court has refused to do. See, e.g., Peffley-Warner, 113 Wash.2d at 249, 778 P.2d 1022; Gallagher, 35 Wash.2d at 514-15, 213 P.2d 621; see also Connell, 127 Wash.2d at 348, 898 P.2d 831 (stating a "meretricious relationship is not the same as a marriage"). Accordingly, we listed five relevant factors to analyze when a meretricious relationship exists: "continuous cohabitation, duration of the relationship, purpose of the relationship, pooling of resources and services for joint projects, and the intent of the parties." Connell, 127 Wash.2d at 346, 898 P.2d 831 (citing Lindsey, 101 Wash.2d at 304-05, 678 P.2d 328; Latham, 87 Wash.2d at 554, 554 P.2d 1057; In re Marriage of DeHollander, 53 Wash.App. 695, 699, 770 P.2d 638 (1989)). These characteristic factors are neither exclusive nor hypertechnical. Rather, these factors are meant to reach all relevant evidence helpful in establishing whether a meretricious relationship exists. Connell, 127 Wash.2d at 346, 898 P.2d 831. Thus, whether relationships are properly characterized as meretricious depends upon the facts of each case. In re Meretricious Relationship of Sutton, 85 Wash.App. 487, 490, 933 P.2d 1069 (1997).

Under Connell, we further established a three-prong analysis for disposing of property when a meretricious relationship terminates. First, the trial court must determine whether a meretricious relationship exists. Second, if such a relationship exists, the trial court then evaluates the interest each party has in the property acquired during the relationship. Third, the trial court then makes a just and equitable distribution of such property. Connell, 127 Wash.2d at 349, 898 P.2d 831.

While property acquired during the meretricious relationship is presumed to belong to both parties, this presumption may be rebutted. Connell, 127 Wash.2d at 351, 898 P.2d 831. We have never divorced the meretricious relationship doctrine from its equitable underpinnings. For example, in both Connell and Peffley-Warner, we stated that "property acquired during the relationship should be before the trial court so that one party is not unjustly enriched at the end of such a relationship." Connell, 127 Wash.2d at 349, 898 P.2d 831 (emphasis added) (citing Peffley-Warner, 113 Wash.2d at 252, 778 P.2d 1022). If the presumption of joint ownership is not rebutted, the courts may look for guidance to the dissolution statute, RCW 26.09.080, for the fair and equitable distribution of property acquired during the meretricious relationship. Connell, 127 Wash.2d at 350, 898 P.2d 831.

In the present cases, we must review and decide whether the trial courts erred in concluding the facts gave rise to meretricious relationships at all. We view this determination as a mixed question of law and fact; as such, the trial court's factual findings are entitled to deference, but the legal conclusions flowing from those findings are reviewed de novo. See, e.g., State v. Armenta, 134 Wash.2d 1, 9, 948 P.2d 1280 (1997) (citing State v. Thorn, 129 Wash.2d 347, 351, 917 P.2d 108 (1996)).

Under Connell, meretricious relationships are defined as stable relationships evidenced by such factors as continuous cohabitation, duration of the relationship, purpose of the relationship, pooling of resources and services for mutual benefit, and the intent of the parties. Connell, 127 Wash.2d at 346, 898 P.2d 831. We now apply the Connell analytic framework, first applying the factors *771 to the trial court's findings regarding Pennington and Van Pevenage.

Continuous Cohabitation: The trial court found Pennington and Van Pevenage began living together in August 1985. Pennington was married to another person until 1990. The parties continued to cohabit until March or April 1991, when Van Pevenage moved out for a period of time. She resumed cohabiting with Pennington until March 1993. Between March 1993 and October 1994, the court found both parties dated other people. The uncontested evidence also establishes Van Pevenage lived with another man during her separation from Pennington. Van Pevenage then moved back in with Pennington for a period of one year. We conclude the continuous cohabitation factor as contemplated by Connell has not been established. Under these circumstances, a court would have great difficulty factoring in the property interest of Pennington's former community, as well as factoring in the periods of separation into the division of property. These facts suggest while Pennington and Van Pevange did cohabit, their cohabitation was sporadic and not continuous enough to evidence a stable cohabiting relationship.

Duration of the Relationship: The trial court found the Pennington/Van Pevenage relationship began in October 1983 when the parties began exclusively dating each other. They began living together in August 1985. The trial court also found the parties separated for a short time in 1991, reconciled, separated again in 1993 through 1994, and reconciled again in October 1994. Thus, their relationship, while not continuous, spanned 12 years. While we agree with the trial court this factor was satisfied, a long-term relationship alone does not require the equitable division of property. Other factors must also justify the need for an equitable division of property acquired by the couple during their relationship.

Intent of the Parties: The trial court found Van Pevenage intended to be in a long-term relationship with the expectation of marriage. Naturally, Pennington presented testimony denying his intent to be in a meretricious relationship. Pennington was married to a different woman for the first five years of his relationship with Van Pevenage. More importantly, after his divorce in 1990, Pennington refused to marry Van Pevenage. Connell contemplates the mutual intent of parties to be in a meretricious relationship. Pennington's refusal, coupled with Van Pevenage's insistence on marrying, belies the existence of the parties' mutual intent to live in a meretricious relationship. Furthermore, Van Pevenage's intent to live in a stable, longterm, cohabiting relationship is also negated by her own actions, particularly her repeated absences from the Yelm home and her relationship with another man. In this case, the evidence does not support concluding the parties had the mutual intent to form a meretricious relationship.

Pooling of Resources: The trial court found Van Pevenage spent money for food, household furnishings, carpeting and tile, and some kitchen utensils. The court also found she cooked meals, cleaned house, and helped with interior decoration. While the evidence establishes the parties shared some living expenses, under Connell these facts are not sufficient to show a significant pooling of resources and services for joint projects.[7] As noted above, the relationship had gaps where no expenses were shared. Van Pevenage has no evidence to suggest she made constant or continuous payments jointly or substantially invested her time and effort into any specific asset so as to create any inequities. Given the evidence presented at trial, we cannot conclude the parties jointly invested their time, effort, or financial resources in any specific asset to justify the equitable division of the parties' property *772 acquired during the course of their relationship.

Purpose of the Relationship: The trial court found the purpose of the Pennington/Van Pevenage relationship included companionship, friendship, love, sex, and mutual support and caring. Although this was significantly disputed by the testimony offered during the trial, we agree with the trial court's conclusion.

One Connell factor is not more important than another. However, when the factors and evidence are taken as a whole, the equitable principles recognized in Connell are not satisfied in this case. Therefore, we conclude the sporadic cohabitation, the instability of the relationship, Van Pevenage's insistence on marriage, Pennington's refusal to marry, Van Pevenage's absences from the home and relationship with another man, the gaps where no expenses were shared, and the absence of constant or continuous copayments or investment of time and effort in any significant asset neither evidence a meretricious relationship nor sufficiently justify the fair and equitable distribution of property acquired during the course of the relationship.

We next apply the Connell factors to the trial court's findings regarding Chesterfield and Nash to decide whether a meretricious relationship was established.

Continuous Cohabitation: The trial court found Chesterfield and Nash moved in together in July 1989 and ceased living together in October 1993. The parties briefly reconciled in 1994 through 1995, when they made plans to marry. However, the parties never married as intended and terminated their relationship in November 1995. The trial court was correct in concluding the parties resided together continuously from July 1989 until October 1993. However, when taken as a whole, the parties' cohabitation was not continuous from 1989 through 1995, but was marked by separation and failed reconciliation.

Duration of the Relationship: The trial court found Chesterfield and Nash had a relationship lasting four years and three months. Additionally, the parties dated from 1986 until 1989, when they moved in together. However, during the first three years of their relationship, Nash dated other women. Similarly, Chesterfield was married, although separated, at the time she began dating Nash. She did not file for divorce until November 1987. The duration of their relationship could help support a conclusion that a meretricious relationship existed between Chesterfield and Nash.

Intent of the Parties: The trial court found Chesterfield and Nash knew they were not married. The trial court found they functioned as one would expect a married couple to function, although the parties did not hold themselves out as spouses. However, the evidence also established Chesterfield was married to another man during her relationship with Nash. These facts are too equivocal to conclusively establish that the parties mutually intended to be in a meretricious relationship.

Pooling of Resources: The trial court found Chesterfield and Nash had a joint checking account for living expenses, into which they both deposited money. During their period of continuous cohabitation, Nash assisted Chesterfield with some work-related travel logs. Chesterfield assisted Nash with his office emergencies, his accounts payable, his role as secretary for his study club, and his office correspondence. The court found the parties resided in Chesterfield's home and shared the mortgage payments. However, the parties maintained separate bank accounts. They also purchased no property jointly. Each maintained his or her own career and financial independence, contributing separately to their respective retirement accounts. When these facts are examined as a whole, the trial court's findings do not fully establish the parties jointly pooled their time, effort, or financial resources enough to require an equitable distribution of property, as contemplated by Connell.

Purpose of the Relationship: The trial court made no findings as to the purpose of the relationship between Chesterfield and Nash.

When the factors and evidence are balanced as a whole, the equitable principles *773 recognized in Connell are not satisfied by the trial court's findings. While the parties' continuous cohabitation and duration of their relationship do evidence a meretricious relationship, the evidence supporting the mutual intent of the parties to be in such a relationship is too equivocal to support such a conclusion. Similarly, the parties maintained separate accounts, purchased no significant assets together, and did not significantly or substantially pool their time and effort to justify the equitable division of property acquired during the course of their relationship. Therefore, we conclude the relationship between Chesterfield and Nash did not constitute a meretricious relationship and the equitable principles recognized in Connell are not triggered by these facts.

CONCLUSION

We, therefore, hold the facts of these cases do not rise to the level of meretricious relationships as envisioned by Connell and Lindsey. Furthermore, we hold neither party made a sufficient showing to justify recovery under other equitable theories.[8] The Court of Appeals in Pennington is affirmed. The Court of Appeals in Chesterfield is reversed. These cases are remanded to the trial courts for further proceedings consistent with this opinion.

GUY, C.J., SMITH, MADSEN, ALEXANDER, TALMADGE, SANDERS, IRELAND, and BRIDGE, JJ., concur.

NOTES

[1] Given this result, it is unnecessary for us to reach the issue of whether the professional goodwill of a business is an asset divisible upon termination of a meretricious relationship.

[2] Evelyn Van Pevenage is petitioner's legal name, although the complaint was filed under the name Sammi Pennington. Petitioner will be referred to in this opinion as "Van Pevenage."

[3] All vehicles were purchased by Pennington and titled in his name. After the relationship ended, Pennington signed title over to Van Pevenage on two vehicles he gave her as gifts.

[4] The period of time Van Pevenage lived elsewhere has been estimated between two weeks and three and one-half months.

[5] Nash testified, based upon his review of canceled checks and bank statements, that he contributed a total amount of $36,046.33 to this account and Chesterfield contributed $15,292.38. Chesterfield testified that Nash contributed more to the account on occasion, but offered no specific estimate.

[6] Washington will recognize common-law marriages validly entered into in other states, but this exception is not applicable to the present cases. Peffley-Warner, 113 Wash.2d at 249, 778 P.2d 1022 (citing In re Welfare of Warren, 40 Wash.2d 342, 344, 243 P.2d 632 (1952); Gallagher, 35 Wash.2d at 514-15, 213 P.2d 621).

[7] When Van Pevenage lived at the Kapowsin residence, Pennington and his wife, Jane Pennington, paid the mortgage and all utilities while Van Pevenage paid for a limited number of household expenses. The second residence in which Van Pevenage and Pennington lived was purchased with Pennington's wages and the sale of the Kapowsin residence. Both the title to the property and the construction loan were in Clark Pennington's name and paid by him. Pennington provided Van Pevenage with automobiles to drive and paid for her automobile insurance. Pennington's company paid Van Pevenage a salary and provided her with medical insurance.

[8] To award a community-property-like division of assets in either of the present cases runs counter to the general equitable principles that form the very foundation of the post-Lindsey meretricious relationship doctrine. Cf. Connell, 127 Wash.2d at 343, 898 P.2d 831 (one cohabitant relocated twice and then managed a bed and breakfast owned by other cohabitant); Lindsey, 101 Wash.2d at 306-07, 678 P.2d 328 (before marrying, cohabitants collaborated on construction of a barn); Foster v. Thilges, 61 Wash.App. 880, 881-82, 812 P.2d 523 (1991) (cohabitants pooled incomes, obtained joint loan to build a new home, and collectively purchased other real property). A review of pre-Lindsey cases involving claims for equitable relief is also instructive. See, e.g., Thornton, 81 Wash.2d at 74-76, 499 P.2d 864 (granting recovery under theory of implied partnership when pseudo spouses operated cattle ranching business together for 16 years); Humphries, 67 Wash.2d at 389-91, 407 P.2d 967 (denying half interest in home to party who cohabited with another party because, "[i]n order to have such an equitable claim, appellant must show that there has been some inequitable conduct...."); Omer v. Omer, 11 Wash.App. 386, 392-93, 523 P.2d 957 (1974) (awarding relief under constructive trust theory when parties were married abroad but later divorced for naturalization purposes, and plaintiff regularly gave her wages to defendant to purchase property titled in his name).

Case-law data current through December 31, 2025. Source: CourtListener bulk data.

↑ + \ No newline at end of file diff --git a/.research/pennington.txt b/.research/pennington.txt new file mode 100644 index 0000000..f18ca15 --- /dev/null +++ b/.research/pennington.txt @@ -0,0 +1 @@ +In Re Marriage of Pennington, 14 P.3d 764 (Wash. 2000) | HallApproved.com Hall Approved Free Access to American Case Law Statutes Free Legal Archive / Washington / Cases / Washington Supreme Court / 2000 / Washington Supreme Court, 2000 Copy citation Free Legal Archive / Washington / Cases / Washington Supreme Court / 2000 / In Re Marriage of Pennington In Re Marriage of Pennington Washington Supreme Court · Decided December 21, 2000 · Johnson 14 P.3d 764 (Pacific Reporter, Third Series) In Re Marriage of Pennington Opinion 14 P.3d 764 (2000) 142 Wash.2d 592 In re the MARRIAGE OF Sammi PENNINGTON, a/k/a Evelyn Lorraine Van Pevenage, Petitioner, and Clark Melvyn Pennington, Respondent. In re the Meretricious Relationship of Diana J. Chesterfield, Respondent, and James E. Nash, Petitioner. No. 67900-2. Supreme Court of Washington, En Banc. Argued February 15, 2000. Decided December 21, 2000. *766 Edwards, Sieh, Smith & Goodfriend, Catherine Wright Smith, Seattle, Charles Wiggins, Kenneth Masters, Bainbridge Island, Troup, Christnacht, Michael Joseph McKasy, Tacoma, for Petitioners. Smith, Alling, Lane, Edward Marshall Lane, Tacoma, Mary Louise Gaudio, Daniel Leward Modeen, Bellevue, for Respondents. *765 JOHNSON, J. In these consolidated cases, we must determine whether the legal requirements to establish a meretricious relationship were satisfied so as to allow for equitable relief under our holdings in Connell v. Francisco, 127 Wash.2d 339 , 898 P.2d 831 (1995) and In re Marriage of Lindsey, 101 Wash.2d 299 , 678 P.2d 328 (1984). We hold the facts of these cases do not support concluding the existence of stable, cohabiting relationships for either of the parties. Furthermore, we hold neither party made a sufficient showing to justify recovery under other equitable theories. We affirm the Court of Appeals in Pennington v. Pennington, 93 Wash.App. 913 , 971 P.2d 98 (1999), reverse the Court of Appeals in Chesterfield v. Nash, 96 Wash. App. 103 , 978 P.2d 551 (1999), and remand both cases to the trial courts. [1] FACTS Pennington v. Pennington Respondent Clark Pennington met petitioner Evelyn Van Pevenage (aka Sammi Pennington) [2] in March 1983. At this time, both Pennington and Van Pevenage were married to other people. Van Pevenage's divorce was finalized in December 1983. Pennington separated from his wife in October *767 1983, but remained married until 1990. Pennington and Van Pevenage began dating each other and, in August 1985, moved in together at Pennington's residence in Kapowsin, Washington. The parties also commenced a sexual relationship. The Kapowsin residence was an airplane hangar with an unfinished apartment upstairs. Clark Pennington and his wife, Jane Pennington, paid the utilities and mortgage payments. Van Pevenage paid for groceries as well as some home furnishings; her income derived from her work as a bartender and lounge manager at various restaurants. Pennington's income derived from his proprietorship of Exacto, Inc., a corporation manufacturing aircraft and machine parts. Van Pevenage testified at trial that towards the end of 1986 Pennington proposed marriage to her and gave her an engagement ring. Pennington denied ever proposing marriage and characterized the gift as a "cocktail ring." In 1987, Pennington purchased a lot in Yelm, Washington. He did so by assuming the underlying real estate contract on the land and agreeing to make cash payments of $700 per month. Pennington made the contract payments from his wages and from rent paid to him by Exacto, Inc. The deed to the property conveyed the land to "Clark M. Pennington, a married man dealing with his separate estate." Ex. 41. Pennington's wife, Jane Pennington, quitclaimed her interest in the Yelm property to him in 1988. Pennington then took out a loan solely in his name to pay off the real estate contract and finance construction of a hangar and a new home on the property. Van Pevenage testified she participated in the interior design of the home, although the housing contractor testified he did not take instructions from her. Pennington and Van Pevenage moved into the Yelm home in December 1988. The home loan payments were made from Pennington's Exacto, Inc. wages and from the sale of the Kapowsin residence. During the course of their relationship, Pennington provided vehicles for Van Pevenage to drive and placed her on his automobile insurance policy. [3] He also named Van Pevenage as the beneficiary of a $50,000 life insurance policy. Van Pevenage acquired credit cards in the name of "Sammi Pennington," and registered Clark and herself in the Yelm telephone book as "Pennington Clark & Sammi." Pennington and Van Pevenage also held joint checking accounts. Pennington denied authorizing Van Pevenage to use his last name for either the telephone book or the credit cards, and testified he had no knowledge she had done so until after the relationship terminated. Van Pevenage lived with Pennington in the Yelm home continuously until 1991. In April 1991, she moved into an apartment, but returned to the Yelm residence shortly thereafter. [4] Several months later, Pennington suffered a stroke and was hospitalized. Van Pevenage temporarily quit her job to help Pennington around the house, but Pennington returned to work only one week after his release from the hospital. After the stroke, Exacto, Inc. provided Van Pevenage with medical insurance coverage and paid her a salary of approximately $1,000 per month, although Van Pevenage did not have an "active role" in the corporation's business. The salary continued intermittently until 1996. After his stroke, Pennington also gave Van Pevenage signing privileges on the corporate account. Van Pevenage moved out of the Yelm residence from March 1993 until October 1994. In May 1994, Van Pevenage commenced a sexual relationship with another man, whom she resided with in September of that year. Pennington dated another woman during this time period. Van Pevenage eventually returned to the Yelm residence for one more year, before leaving again in October 1995. Her relationship with Pennington was not sexual during this last year. In 1996, Van Pevenage filed a complaint in superior court for dissolution of a meretricious *768 relationship between Pennington and herself. The trial court concluded such a relationship did exist, determined that certain property acquired during the relationship should be treated as community property for the purpose of making a just and equitable division of such property, and awarded Van Pevenage a total judgment of $214,200, less amounts already received. Pennington appealed, and the Court of Appeals reversed. Pennington, 93 Wash.App. 913 , 971 P.2d 98 . The Court of Appeals held no meretricious relationship existed between Pennington and Van Pevenage, primarily because "during most of the period that the trial court terms `meretricious,' the parties were not free to marry legally, did not intend to marry, or punctuated their living together with a third party relationship." Pennington, 93 Wash.App. at 919 , 971 P.2d 98 . Van Pevenage filed a petition for review with this court, which we granted. Chesterfield v. Nash Petitioner James Nash and respondent Diana Chesterfield began a casual dating relationship in August 1986. A few months later the relationship became sexually intimate. Chesterfield worked as a salesperson at Nordstrom, and Nash operated a dental practice he had purchased in 1985. Chesterfield was married, although separated, at the time she began dating Nash. Chesterfield filed for divorce in November 1987. The parties dated from 1986 until 1989, although Nash dated other women during this time period. In July 1989, Nash and Chesterfield moved into a home purchased the previous year by Chesterfield. While living together, Nash and Chesterfield opened a joint checking account to which they both contributed funds. The account was opened for the purpose of funding living expenses; it was used to pay the mortgage and taxes on the house, as well as groceries, utility bills, and other miscellaneous matters. Contributions to the account were initially equal, but over time Nash contributed more than Chesterfield. [5] Nash testified he also paid nearly all expenses for their numerous vacations, and a disproportionate amount of their dining out expenses. Chesterfield had a profit sharing plan at Nordstrom, but refused to invest those funds in Nash's dental practice unless the two were married. Chesterfield also testified she would not invest in a house with Nash until they were married. Overall, Chesterfield's spending patterns did not change during the period of cohabitation, although she received promotions and pay increases at Nordstrom. Nash and Chesterfield periodically assisted each other professionally. Nash aided Chesterfield with work-related travel logs and offered her the use of the computer at his dental practice. Chesterfield aided Nash as a temporary dental assistant, helped process accounts payable for several months, and performed word processing tasks. Nash offered to compensate Chesterfield for her help, but she refused. Nash and Chesterfield ceased living together in October 1993. Chesterfield closed the joint account and made a mortgage payment with the remaining funds. In 1994, Nash and Chesterfield briefly reconciled and began dating again, although they did not resume living together. They discussed marriage and Nash purchased a diamond for Chesterfield, but in November 1995 they permanently ended their relationship. Chesterfield filed a petition for disposition of property rights of a meretricious relationship in superior court. The trial court found Nash and Chesterfield had a meretricious relationship, certain property acquired during that relationship should be treated as community property for the purposes of making a just and equitable division of that property, and a 60/40 percent ratio in favor of Nash was the appropriate basis of division. The trial court entered a judgment of $75,594 plus costs, in favor of Chesterfield. Included in the court's valuation and division of property was a $40,000 increase in the goodwill of Nash's dental practice. *769 Nash timely appealed, and the Court of Appeals affirmed. Chesterfield, 96 Wash. App. at 117 , 978 P.2d 551 . The Court of Appeals concluded Nash and Chesterfield had a meretricious relationship primarily because they "lived together continuously in a stable, mutually-supportive relationship for longer than four years, functioning as one would expect a married couple to function with regard to work." Chesterfield, 96 Wash. App. at 109 , 978 P.2d 551 . Although the Court of Appeals conceded "Nash's name did not appear on the title of the house in which they lived, and that Chesterfield and Nash did not hold themselves out as being married or commingle their resources for purposes other than living expenses," it found this insignificant. Chesterfield, 96 Wash.App. at 109 , 978 P.2d 551 . The Court of Appeals held the trial court properly divided the goodwill of the dental practice. Chesterfield, 96 Wash.App. at 111-17 , 978 P.2d 551 . Nash petitioned this court for review, which we granted and consolidated with Pennington . ANALYSIS Our Legislature requires a solemnized "civil contract" in order for a marriage to be valid. RCW 26.04.010(1); see also RCW 26.04.050, .120, .130; Meton v. Indus. Ins. Dep't, 104 Wash. 652, 655 , 177 P. 696 (1919); In re Estate of McLaughlin, 4 Wash. 570, 588-89 , 30 P. 651 (1892); Roe v. Ludtke Trucking, Inc., 46 Wash.App. 816, 819 , 732 P.2d 1021 (1987). Common-law marriage is not recognized under Washington law. Peffley-Warner v. Bowen, 113 Wash.2d 243, 249 , 778 P.2d 1022 (1989); In re Estate of Gallagher, 35 Wash.2d 512, 514-15 , 213 P.2d 621 (1950). [6] Wholly unrelated to either kind of marriage, courts have recognized the existence of meretricious relationships, which this court has determined to be stable, cohabiting relationships. See Connell, 127 Wash.2d at 346 , 898 P.2d 831 . For nearly a century, Washington law presumed all property acquired by unmarried cohabitants belonged to the holder of the legal title. See, e.g., Latham v. Hennessey, 87 Wash.2d 550, 552-53 , 554 P.2d 1057 (1976); Creasman v. Boyle, 31 Wash.2d 345, 358 , 196 P.2d 835 (1948); Engstrom v. Peterson, 107 Wash. 523, 530 , 182 P. 623 (1919); Stans v. Baitey, 9 Wash. 115, 119 , 37 P. 316 (1894). However, even when this presumption applied, courts recognized a variety of exceptions to this presumption. See Latham, 87 Wash.2d at 553-54 , 554 P.2d 1057 . Among these exceptions were: (1) tracing source of funds, West v. Knowles, 50 Wash.2d 311, 313 , 311 P.2d 689 (1957); (2) implied partnership/joint venture, In re Estate of Thornton, 81 Wash.2d 72, 78-81 , 499 P.2d 864 (1972); (3) resulting trusts, Walberg v. Mattson, 38 Wash.2d 808, 812-14 , 232 P.2d 827 (1951); (4) constructive trusts, Humphries v. Riveland, 67 Wash.2d 376, 389-90 , 407 P.2d 967 (1965); (5) tenancy in common, Shull v. Shepherd, 63 Wash.2d 503, 506 , 387 P.2d 767 (1963); and (6) contract theory, Dahlgren v. Blomeen, 49 Wash.2d 47, 50-52 , 298 P.2d 479 (1956). In 1984, this court discarded this presumption. Lindsey, 101 Wash.2d 299 , 678 P.2d 328 . Lindsey involved a couple who commenced an intimate relationship in 1974, legally married in 1976, and divorced in 1982. Lindsey, 101 Wash.2d at 300 , 678 P.2d 328 . The court declined to presume that property acquired before the legal marriage belonged to the holder of title, instead holding "that courts must `examine the [meretricious] relationship and the property accumulations and make a just and equitable disposition of the property.'" Lindsey, 101 Wash.2d at 304 , 678 P.2d 328 (quoting Latham, 87 Wash.2d at 554 , 554 P.2d 1057 ). As a meretricious relationship was conceded by both parties, this court remanded for a determination of how insurance proceeds from a building the couple helped construct should be divided. Lindsey, 101 Wash.2d at 306-07 , 678 P.2d 328 . This court again considered the issue of meretricious relationships in Connell, 127 Wash.2d 339 , 898 P.2d 831 . Connell , like *770 Lindsey , involved an uncontested meretricious relationship. Connell, 127 Wash.2d at 346 , 898 P.2d 831 . Connell and Francisco had an intimate relationship and lived together from 1983 until 1990. In 1986, they moved to Whidbey Island, Washington, where Connell managed a bed and breakfast purchased by Francisco's corporation. Connell, 127 Wash.2d at 343 , 898 P.2d 831 . We characterized meretricious as a "stable, marital-like relationship where both parties cohabit with knowledge that a lawful marriage between them does not exist." Connell, 127 Wash.2d at 346 , 898 P.2d 831 (citing Lindsey, 101 Wash.2d at 304 , 678 P.2d 328 ; Harry M. Cross, The Community Property Law in Washington (Revised 1985), 61 Wash.L.Rev. 13, 23 (1986)). The use of the term "marital-like" is a mere analogy because defining meretricious relationships as related to marriage would create a de facto common-law marriage, which this court has refused to do. See, e.g., Peffley-Warner, 113 Wash.2d at 249 , 778 P.2d 1022 ; Gallagher, 35 Wash.2d at 514-15 , 213 P.2d 621 ; see also Connell, 127 Wash.2d at 348 , 898 P.2d 831 (stating a "meretricious relationship is not the same as a marriage"). Accordingly, we listed five relevant factors to analyze when a meretricious relationship exists: "continuous cohabitation, duration of the relationship, purpose of the relationship, pooling of resources and services for joint projects, and the intent of the parties." Connell, 127 Wash.2d at 346 , 898 P.2d 831 (citing Lindsey, 101 Wash.2d at 304-05 , 678 P.2d 328 ; Latham, 87 Wash.2d at 554 , 554 P.2d 1057 ; In re Marriage of DeHollander, 53 Wash.App. 695, 699 , 770 P.2d 638 (1989)). These characteristic factors are neither exclusive nor hypertechnical. Rather, these factors are meant to reach all relevant evidence helpful in establishing whether a meretricious relationship exists. Connell, 127 Wash.2d at 346 , 898 P.2d 831 . Thus, whether relationships are properly characterized as meretricious depends upon the facts of each case. In re Meretricious Relationship of Sutton, 85 Wash.App. 487, 490 , 933 P.2d 1069 (1997). Under Connell , we further established a three-prong analysis for disposing of property when a meretricious relationship terminates. First, the trial court must determine whether a meretricious relationship exists. Second, if such a relationship exists, the trial court then evaluates the interest each party has in the property acquired during the relationship. Third, the trial court then makes a just and equitable distribution of such property. Connell, 127 Wash.2d at 349 , 898 P.2d 831 . While property acquired during the meretricious relationship is presumed to belong to both parties, this presumption may be rebutted. Connell, 127 Wash.2d at 351 , 898 P.2d 831 . We have never divorced the meretricious relationship doctrine from its equitable underpinnings. For example, in both Connell and Peffley-Warner , we stated that "property acquired during the relationship should be before the trial court so that one party is not unjustly enriched at the end of such a relationship." Connell, 127 Wash.2d at 349 , 898 P.2d 831 (emphasis added) (citing Peffley-Warner, 113 Wash.2d at 252 , 778 P.2d 1022 ). If the presumption of joint ownership is not rebutted, the courts may look for guidance to the dissolution statute, RCW 26.09.080, for the fair and equitable distribution of property acquired during the meretricious relationship. Connell, 127 Wash.2d at 350 , 898 P.2d 831 . In the present cases, we must review and decide whether the trial courts erred in concluding the facts gave rise to meretricious relationships at all. We view this determination as a mixed question of law and fact; as such, the trial court's factual findings are entitled to deference, but the legal conclusions flowing from those findings are reviewed de novo. See, e.g., State v. Armenta, 134 Wash.2d 1, 9 , 948 P.2d 1280 (1997) (citing State v. Thorn, 129 Wash.2d 347, 351 , 917 P.2d 108 (1996)). Under Connell , meretricious relationships are defined as stable relationships evidenced by such factors as continuous cohabitation, duration of the relationship, purpose of the relationship, pooling of resources and services for mutual benefit, and the intent of the parties. Connell, 127 Wash.2d at 346 , 898 P.2d 831 . We now apply the Connell analytic framework, first applying the factors *771 to the trial court's findings regarding Pennington and Van Pevenage. Continuous Cohabitation : The trial court found Pennington and Van Pevenage began living together in August 1985. Pennington was married to another person until 1990. The parties continued to cohabit until March or April 1991, when Van Pevenage moved out for a period of time. She resumed cohabiting with Pennington until March 1993. Between March 1993 and October 1994, the court found both parties dated other people. The uncontested evidence also establishes Van Pevenage lived with another man during her separation from Pennington. Van Pevenage then moved back in with Pennington for a period of one year. We conclude the continuous cohabitation factor as contemplated by Connell has not been established. Under these circumstances, a court would have great difficulty factoring in the property interest of Pennington's former community, as well as factoring in the periods of separation into the division of property. These facts suggest while Pennington and Van Pevange did cohabit, their cohabitation was sporadic and not continuous enough to evidence a stable cohabiting relationship. Duration of the Relationship : The trial court found the Pennington/Van Pevenage relationship began in October 1983 when the parties began exclusively dating each other. They began living together in August 1985. The trial court also found the parties separated for a short time in 1991, reconciled, separated again in 1993 through 1994, and reconciled again in October 1994. Thus, their relationship, while not continuous, spanned 12 years. While we agree with the trial court this factor was satisfied, a long-term relationship alone does not require the equitable division of property. Other factors must also justify the need for an equitable division of property acquired by the couple during their relationship. Intent of the Parties : The trial court found Van Pevenage intended to be in a long-term relationship with the expectation of marriage. Naturally, Pennington presented testimony denying his intent to be in a meretricious relationship. Pennington was married to a different woman for the first five years of his relationship with Van Pevenage. More importantly, after his divorce in 1990, Pennington refused to marry Van Pevenage. Connell contemplates the mutual intent of parties to be in a meretricious relationship. Pennington's refusal, coupled with Van Pevenage's insistence on marrying, belies the existence of the parties' mutual intent to live in a meretricious relationship. Furthermore, Van Pevenage's intent to live in a stable, longterm, cohabiting relationship is also negated by her own actions, particularly her repeated absences from the Yelm home and her relationship with another man. In this case, the evidence does not support concluding the parties had the mutual intent to form a meretricious relationship. Pooling of Resources : The trial court found Van Pevenage spent money for food, household furnishings, carpeting and tile, and some kitchen utensils. The court also found she cooked meals, cleaned house, and helped with interior decoration. While the evidence establishes the parties shared some living expenses, under Connell these facts are not sufficient to show a significant pooling of resources and services for joint projects. [7] As noted above, the relationship had gaps where no expenses were shared. Van Pevenage has no evidence to suggest she made constant or continuous payments jointly or substantially invested her time and effort into any specific asset so as to create any inequities. Given the evidence presented at trial, we cannot conclude the parties jointly invested their time, effort, or financial resources in any specific asset to justify the equitable division of the parties' property *772 acquired during the course of their relationship. Purpose of the Relationship: The trial court found the purpose of the Pennington/Van Pevenage relationship included companionship, friendship, love, sex, and mutual support and caring. Although this was significantly disputed by the testimony offered during the trial, we agree with the trial court's conclusion. One Connell factor is not more important than another. However, when the factors and evidence are taken as a whole, the equitable principles recognized in Connell are not satisfied in this case. Therefore, we conclude the sporadic cohabitation, the instability of the relationship, Van Pevenage's insistence on marriage, Pennington's refusal to marry, Van Pevenage's absences from the home and relationship with another man, the gaps where no expenses were shared, and the absence of constant or continuous copayments or investment of time and effort in any significant asset neither evidence a meretricious relationship nor sufficiently justify the fair and equitable distribution of property acquired during the course of the relationship. We next apply the Connell factors to the trial court's findings regarding Chesterfield and Nash to decide whether a meretricious relationship was established. Continuous Cohabitation: The trial court found Chesterfield and Nash moved in together in July 1989 and ceased living together in October 1993. The parties briefly reconciled in 1994 through 1995, when they made plans to marry. However, the parties never married as intended and terminated their relationship in November 1995. The trial court was correct in concluding the parties resided together continuously from July 1989 until October 1993. However, when taken as a whole, the parties' cohabitation was not continuous from 1989 through 1995, but was marked by separation and failed reconciliation. Duration of the Relationship: The trial court found Chesterfield and Nash had a relationship lasting four years and three months. Additionally, the parties dated from 1986 until 1989, when they moved in together. However, during the first three years of their relationship, Nash dated other women. Similarly, Chesterfield was married, although separated, at the time she began dating Nash. She did not file for divorce until November 1987. The duration of their relationship could help support a conclusion that a meretricious relationship existed between Chesterfield and Nash. Intent of the Parties: The trial court found Chesterfield and Nash knew they were not married. The trial court found they functioned as one would expect a married couple to function, although the parties did not hold themselves out as spouses. However, the evidence also established Chesterfield was married to another man during her relationship with Nash. These facts are too equivocal to conclusively establish that the parties mutually intended to be in a meretricious relationship. Pooling of Resources: The trial court found Chesterfield and Nash had a joint checking account for living expenses, into which they both deposited money. During their period of continuous cohabitation, Nash assisted Chesterfield with some work-related travel logs. Chesterfield assisted Nash with his office emergencies, his accounts payable, his role as secretary for his study club, and his office correspondence. The court found the parties resided in Chesterfield's home and shared the mortgage payments. However, the parties maintained separate bank accounts. They also purchased no property jointly. Each maintained his or her own career and financial independence, contributing separately to their respective retirement accounts. When these facts are examined as a whole, the trial court's findings do not fully establish the parties jointly pooled their time, effort, or financial resources enough to require an equitable distribution of property, as contemplated by Connell . Purpose of the Relationship: The trial court made no findings as to the purpose of the relationship between Chesterfield and Nash. When the factors and evidence are balanced as a whole, the equitable principles *773 recognized in Connell are not satisfied by the trial court's findings. While the parties' continuous cohabitation and duration of their relationship do evidence a meretricious relationship, the evidence supporting the mutual intent of the parties to be in such a relationship is too equivocal to support such a conclusion. Similarly, the parties maintained separate accounts, purchased no significant assets together, and did not significantly or substantially pool their time and effort to justify the equitable division of property acquired during the course of their relationship. Therefore, we conclude the relationship between Chesterfield and Nash did not constitute a meretricious relationship and the equitable principles recognized in Connell are not triggered by these facts. CONCLUSION We, therefore, hold the facts of these cases do not rise to the level of meretricious relationships as envisioned by Connell and Lindsey . Furthermore, we hold neither party made a sufficient showing to justify recovery under other equitable theories. [8] The Court of Appeals in Pennington is affirmed. The Court of Appeals in Chesterfield is reversed. These cases are remanded to the trial courts for further proceedings consistent with this opinion. GUY, C.J., SMITH, MADSEN, ALEXANDER, TALMADGE, SANDERS, IRELAND, and BRIDGE, JJ., concur. NOTES [1] Given this result, it is unnecessary for us to reach the issue of whether the professional goodwill of a business is an asset divisible upon termination of a meretricious relationship. [2] Evelyn Van Pevenage is petitioner's legal name, although the complaint was filed under the name Sammi Pennington. Petitioner will be referred to in this opinion as "Van Pevenage." [3] All vehicles were purchased by Pennington and titled in his name. After the relationship ended, Pennington signed title over to Van Pevenage on two vehicles he gave her as gifts. [4] The period of time Van Pevenage lived elsewhere has been estimated between two weeks and three and one-half months. [5] Nash testified, based upon his review of canceled checks and bank statements, that he contributed a total amount of $36,046.33 to this account and Chesterfield contributed $15,292.38. Chesterfield testified that Nash contributed more to the account on occasion, but offered no specific estimate. [6] Washington will recognize common-law marriages validly entered into in other states, but this exception is not applicable to the present cases. Peffley-Warner, 113 Wash.2d at 249 , 778 P.2d 1022 (citing In re Welfare of Warren, 40 Wash.2d 342, 344 , 243 P.2d 632 (1952); Gallagher, 35 Wash.2d at 514-15 , 213 P.2d 621 ). [7] When Van Pevenage lived at the Kapowsin residence, Pennington and his wife, Jane Pennington, paid the mortgage and all utilities while Van Pevenage paid for a limited number of household expenses. The second residence in which Van Pevenage and Pennington lived was purchased with Pennington's wages and the sale of the Kapowsin residence. Both the title to the property and the construction loan were in Clark Pennington's name and paid by him. Pennington provided Van Pevenage with automobiles to drive and paid for her automobile insurance. Pennington's company paid Van Pevenage a salary and provided her with medical insurance. [8] To award a community-property-like division of assets in either of the present cases runs counter to the general equitable principles that form the very foundation of the post- Lindsey meretricious relationship doctrine. Cf. Connell, 127 Wash.2d at 343 , 898 P.2d 831 (one cohabitant relocated twice and then managed a bed and breakfast owned by other cohabitant); Lindsey, 101 Wash.2d at 306-07 , 678 P.2d 328 (before marrying, cohabitants collaborated on construction of a barn); Foster v. Thilges, 61 Wash.App. 880, 881-82 , 812 P.2d 523 (1991) (cohabitants pooled incomes, obtained joint loan to build a new home, and collectively purchased other real property). A review of pre- Lindsey cases involving claims for equitable relief is also instructive. See, e.g., Thornton, 81 Wash.2d at 74-76 , 499 P.2d 864 (granting recovery under theory of implied partnership when pseudo spouses operated cattle ranching business together for 16 years); Humphries, 67 Wash.2d at 389-91 , 407 P.2d 967 (denying half interest in home to party who cohabited with another party because, "[i]n order to have such an equitable claim, appellant must show that there has been some inequitable conduct...."); Omer v. Omer, 11 Wash.App. 386, 392-93 , 523 P.2d 957 (1974) (awarding relief under constructive trust theory when parties were married abroad but later divorced for naturalization purposes, and plaintiff regularly gave her wages to defendant to purchase property titled in his name). Case-law data current through December 31, 2025. Source: CourtListener bulk data . A public interest project of Aaron Hall, Attorney at Law © 2026 About Federal Minnesota California New York Texas Terms Data from CourtListener / Free Law Project ↑ \ No newline at end of file diff --git a/.research/rockwell2007.html b/.research/rockwell2007.html new file mode 100644 index 0000000..2249d5e --- /dev/null +++ b/.research/rockwell2007.html @@ -0,0 +1,353 @@ + + + + + + IN RE MARRIAGE OF ROCKWEL | 170 P.3d... | 0p3d5721741 | Leagle.com + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + +
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+ IN RE MARRIAGE OF ROCKWELL +

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+ No. 56954-6-I. +
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170 P.3d 572 (2007)

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141 Wn.App. 235

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In re the Matter of the MARRIAGE OF Carmen P. ROCKWELL, Respondent, and +Peter G. Rockwell, Appellant.

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Court of Appeals of Washington, Division 1.

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Publication Ordered October 19, 2007.

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Attorney(s) appearing for the Case

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Patricia S. Novotny, Attorney at Law, Seattle, WA, for Appellant.

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Cynthia B. Whitaker, Law Offices of Cynthia B. Whitaker, Catherine Wright Smith, Edwards Sieh Smith & Goodfriend PS, Seattle, WA, for Respondent.

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¶ 1 Peter Rockwell challenges the fairness of a 60/40 division of property in the dissolution of a long term marriage. He argues the trial court improperly considered his future earning capacity as a factor in the overall fairness of the division. He claims the trial court erred in making an adjustment for social security benefits...

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    + + + + \ No newline at end of file diff --git a/.research/rockwell2007.txt b/.research/rockwell2007.txt new file mode 100644 index 0000000..c86b270 --- /dev/null +++ b/.research/rockwell2007.txt @@ -0,0 +1 @@ +IN RE MARRIAGE OF ROCKWEL | 170 P.3d... | 0p3d5721741 | Leagle.com Menu Home Featured Decisions Latest Decisions Browse Decisions Advanced Search Sign in Home Browse Decisions P.3d 170 P.3d 170 P.3d 572 (2007) IN RE MARRIAGE OF ROCKWELL No. 56954-6-I. View Case 170 P.3d 572 (2007) 141 Wn.App. 235 In re the Matter of the MARRIAGE OF Carmen P. ROCKWELL, Respondent, and Peter G. Rockwell, Appellant. Court of Appeals of Washington, Division 1. https://leagle.com/images/logo.png August 27, 2007. Publication Ordered October 19, 2007. Attorney(s) appearing for the Case Patricia S. Novotny, Attorney at Law, Seattle, WA, for Appellant. Cynthia B. Whitaker, Law Offices of Cynthia B. Whitaker, Catherine Wright Smith, Edwards Sieh Smith & Goodfriend PS, Seattle, WA, for Respondent. APPELWICK , C.J. ¶ 1 Peter Rockwell challenges the fairness of a 60/40 division of property in the dissolution of a long term marriage. He argues the trial court improperly considered his future earning capacity as a factor in the overall fairness of the division. He claims the trial court erred in making an adjustment for social security benefits... Let's get started Welcome to the leading source of independent legal reporting Sign on now to see your case. Or view more than 10 million decisions and orders. Updated daily. Uncompromising quality. Complete, Accurate, Current. Subscribe Now! Listed below are the cases that are cited in this Featured Case. Click the citation to see the full text of the cited case. Citations are also linked in the body of the Featured Case. Cited Cases No Cases Found Listed below are those cases in which this Featured Case is cited. Click on the case name to see the full text of the citing case. Citing Cases Copyright © 2026, Leagle, Inc. Disclaimer Terms of Use Privacy Statement Corporate Social Responsibility About Us Contact Us \ No newline at end of file diff --git a/.research/rockwell2007_at.html b/.research/rockwell2007_at.html new file mode 100644 index 0000000..d6f1190 --- /dev/null +++ b/.research/rockwell2007_at.html @@ -0,0 +1,151 @@ + + + + + + +archive.ph + + + + + + + + + +
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    +You have sent too many requests in a given amount of time. + diff --git a/.research/rockwell2007_vlex.txt b/.research/rockwell2007_vlex.txt new file mode 100644 index 0000000..242ac8b --- /dev/null +++ b/.research/rockwell2007_vlex.txt @@ -0,0 +1 @@ +In re Marriage of Rockwell (In re Marriage of Rockwell, 170 P.3d 572, 141 Wn. App. 235 (Wash. App. 2007)) - vLex United States VINCENT AI Legal Research Coverage DOCKET ALARM Login Sign Up Home Case Law In re Marriage of Rockwell Document Cited authorities (6) Cited in (61) Precedent Map Related Court Washington Court of Appeals Writing for the Court Appelwick Citation In re Marriage of Rockwell, 170 P.3d 572, 141 Wn. App. 235 (Wash. App. 2007) Decision Date 27 August 2007 Docket Number No. 56954-6-I. Parties In re the Matter of the MARRIAGE OF Carmen P. ROCKWELL, Respondent, and Peter G. Rockwell, Appellant. 170 P.3d 572 141 Wn. App. 235 In re the Matter of the MARRIAGE OF Carmen P. ROCKWELL , Respondent , and Peter G. Rockwell , Appellant . No. 56954-6 -I. Court of Appeals of Washington, Division 1 . August 27, 2007 . Publication Ordered October 19, 2007 . Patricia S. Novotny , Attorney at Law, Seattle, WA, for Appellant . Cynthia B. Whitaker , Law Offices of Cynthia B. Whitaker , Catherine Wright Smith , Edwards Sieh Smith & Goodfriend PS , Seattle, WA, for Respondent . APPELWICK , C.J. ¶ 1 Peter Rockwell challenges the fairness of a 60/40 division of property in the dissolution of a long term marriage. He argues the trial court improperly considered his future earning capacity as a factor in the overall fairness of the division. He claims the trial court erred in making an adjustment for social security benefits that his wife would have received but for her type of federal pension. Carmen Rockwell cross-appeals, arguing that the court erred when it chose the subtraction method to characterize and value her federal pension. We reverse the trial court 's use of the subtraction method for pension characterization and valuation, but affirm on all other issues and remand for further proceedings. FACTS ¶ 2 Peter and Carmen Rockwell were married from 1978 until 2004 , a total of 26 years. Carmen 1 had been employed in the federal civil service for 16 years prior to the marriage. During those 16 years, she took two breaks from this service, one for a period of about fourteen months, and another for a period of just under five years. She continued in this field for 24 more years during their marriage. Peter has bachelor's degrees in mechanical engineering and liberal arts. He worked as an engineer in Washington, D.C. before seeking a position in technical sales. In order to advance Carmen's career, the couple moved to New York in 1984 , and then to Seattle in 1986 . Each time, Peter gave up his current employment and sought re-employment in their new location. In 1999 , when Peter was 48, he was laid off. In his last year of employment, he had earned a $72,000 salary and a commission of about $18,000. He searched for employment in similar fields but without success, and stopped seeking employment after the spring of 2002 . ¶ 3 Carmen retired in 2002 at age 60, testifying to health concerns that kept her from continuing her employment. She had advanced from a position as a GS-3 clerk to a GS-15 executive, for which she earned a $120,000 salary as the head of the Northwest Regional Office of Civil Rights . Because she was enrolled in the Civil Service Retirement System (CSRS) , she earned a substantial pension that is in lieu of any social security benefits. This pension is now in "pay status." ¶ 4 In 2004 , Carmen filed for dissolution of the marriage. At trial, the parties and their experts presented lengthy testimony regarding Carmen's career and health, Peter's career, job search and health, the future possible income streams of both parties , the community debts, and the tangible assets available to each. The trial court received evidence on various real and personal properties, including the family home, Carmen's IRA and Thrift Savings Plan, Peter's contributory and rollover IRA's, two automobiles, rental proceeds, life insurance policies, Peter's disability insurance policy, frequent flier miles, and Carmen's CSRS pension. ¶ 5 In its oral ruling issued on June 24, 2005 , 2 the trial court stated that it was "back [ing] out the Social Security contribution assessment for — that Mr. Kessler provided, that's $159,464." This is the value of social security that Carmen would have received if she was not receiving her particular type of federal pension. The trial court "compensated" her for that amount in its written findings of fact. ¶ 6 In addressing the division of the pension, the trial court noted Peter's entitlement to Social Security benefits and their potential to increase, Carmen's lack of Social Security benefits due to her type of pension, and Peter's inheritance funds that he gifted to the community. It accepted the "subtraction method" that Peter's actuary expert used to value Carmen's pension, finding that 92 percent of the pension was community property and 8 percent was Carmen's separate property. The trial court concluded that it was fair and equitable to divide the community property portion of the pension 60 percent to Carmen and 40 percent to Peter, and to award Carmen her separate property portion of the pension. This meant that Peter is to receive 36.8 percent of the gross value of the pension. ¶ 7 Both parties moved for reconsideration of the oral ruling filing a motion and response to the same on July 26, 2005 . There are no significant differences between what the parties raised in their motions for reconsideration and the issues raised on appeal. The trial court denied Peter's motion for reconsideration in its entirety. The trial court also denied Carmen's motion for reconsideration in its entirety, but did revise the proposed order to reflect that the pension was 8 percent Carmen's separate property and 92 percent community property. ¶ 8 The trial court issued its written findings of fact on August 26, 2005 . Based on those findings, the trial court stated " [g] iven the difference in age, earning capacity, physical condition, and that husband had the ability to earn income and save for retirement in the future, it is fair and equitable to divide the community property 60 percent to wife and 40 percent to husband." It also ordered the family home to be sold in order to provide liquidity to both parties . ¶ 9 Neither party moved for reconsideration of the written findings of fact. Peter filed his notice of appeal on September 26, 2005 . Carmen filed her notice of cross-appeal on October 4, 2005 . ANALYSIS I. Standard of Review ¶ 10 Appellate courts apply the substantial evidence standard of review to findings of fact made by the trial judge. See Washington Family Law Deskbook , 2nd Ed. § 65.4 (1) at 65-9 . As long as the findings of fact are supported by substantial evidence, they will not be disturbed on appeal. Thorndike v. Hesperian Orchards, Inc. , 54 Wash.2d 570, 575 , 343 P.2d 183 ( 1959 ) . "Substantial evidence exists if the record contains evidence of a sufficient quantity to persuade a fair-minded, rational person of the truth of the declared premise." In re Marriage of Griswold , 112 Wash.App. 333, 339 , 48 P.3d 1018 ( 2002 ) . Where the trial court has weighed the evidence, the reviewing court 's role is to simply determine whether substantial evidence supports the findings of fact, and if so, whether the findings in turn support the trial court 's conclusions of law. In re Marriage of Greene , 97 Wash.App. 708 , 986 P.2d 144 ( 1999 ) . A court should "not substitute [its] judgment for the trial court 's, weigh the evidence, or adjudge witness credibility." Id. at 714 , 986 P.2d 144 ( citing In re Marriage of Rich , 80 Wash.App. 252, 259 , 907 P.2d 1234 ( 1996 ) ) . ¶ 11 The trial court 's distribution of property in a dissolution action is guided by statute , which requires it to consider multiple factors in reaching an equitable conclusion. These factors include (1) the nature and extent of the community property, (2) the nature and extent of the separate property, (3) the duration of the marriage, and (4) the economic circumstances of each spouse at the time the division of the property is to become effective. RCW 26.09.080 . In weighing these factors, the court must make a "just and equitable" distribution of the marital property. RCW 26.09.080 . In doing so, the trial court has broad discretion in distributing the marital property, and its decision will be reversed only if there is a manifest abuse of discretion. In re Griswold , 112 Wash. App. at 339 , 48 P.3d 1018 ( citing In re Marriage of Kraft , 119 Wash.2d 438, 450 , 832 P.2d 871 ( 1992 ) ) . A manifest abuse of discretion occurs when the discretion was exercised on untenable grounds. In re Marriage of Muhammad , 153 Wash.2d 795, 803 , 108 P.3d 779 ( 2005 ) . If the decree results in a patent disparity in the parties ' economic circumstances, a manifest abuse of discretion has occurred. In re Marriage of Pea , 17 Wash. App. 728, 731 , 566 P.2d 212 ( 1977 ) . ¶ 12 However, the court is not required to divide community property equally. In re Marriage of White , 105 Wash.App. 545, 549 , 20 P.3d 481 ( 2001 ) . In a long term marriage of 25 years or more, the trial court 's objective is to place the parties in roughly equal financial positions for the rest of their lives. Washington Family Law Deskbook , § 32.3 (3) at 17 (2d. ed.2000) ; see also Sullivan v. Sullivan , 52 Wash. 160, 164 , 100 P. 321 ( 1909 ) ( finding that for a marriage lasting over 25 years, "after [which] a husband and wife have toiled on together for upwards of a quarter of a century in accumulating property . . . the ultimate duty of the court is to make a fair and equitable division under all the circumstances" ) . The longer the marriage, the more likely a court will make a disproportionate distribution of the community property. Where one spouse is older, semi-retired and dealing with ill health, and the other spouse is employable, the court does not abuse its discretion in ordering an unequal division of community property. In re Marriage of Schweitzer , 81 Wash.App. 589 , 915 P.2d 575 ( 1996 ) . II. Social Security Benefits ¶ 13 Peter assigns error to the trial court 's consideration of Carmen's social security benefits. First, he assigns error to the following finding of fact: 2.8. 13.e. Wife is not entitled to receive Social Security benefits as her pension is in lieu of Social Security benefits. The present value of wife's social security benefits is $159,464. The court finds it is fair and equitable to compensate wife in this amount, since husband will receive social security benefits. ¶ 14 Mr. Kessler, Carmen's expert, testified that Carmen's type of federal pension is in lieu of Social Security. He valued the Social Security ... 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Peterson (In re Peterson) United States California Court of Appeals January 11, 2016 ... 243 Cal.App.4th 923 197 Cal.Rptr.3d 588 In re MARRIAGE OF John and Annette PETERSON. John Peterson, Respondent, v. Annette Peterson, Appellant. B259322 Court of Appeal, Second District, Division 4, ... at pp. 119–120, 322 P.3d 546.) Similarly, in In re Marriage of Rockwell (Wash.Ct.App.2007) 141 Wash.App. 235, 170 P.3d 572 ( Rockwell ), the wife participated in CSRS and the husband contributed to Social Security. The ... ... Maziar v. Wash. State Dep't of Corr. United States Washington Court of Appeals March 24, 2014 ... ... “Appellate courts apply the substantial evidence standard of review to findings of fact made by the trial judge.” In re Marriage of Rockwell , 141 Wash.App. 235, 242, 170 P.3d 572 (2007). Substantial evidence is defined as a quantum of evidence sufficient to ... ... Underwood v. Underwood United States Washington Court of Appeals June 3, 2014 ... ... ¶ 1 Robert Underwood appeals multiple trial court orders entered in proceedings related to the dissolution of his marriage to Kara Underwood. We hold that the trial court erred in allowing the parties' two teenage children to determine the amount of their residential time ... Rockwell , 141 Wash.App. 235, 242, 170 P.3d 572 (2007). A just and equitable division “does not require mathematical precision, but rather fairness, based ... ... Thomasi v. Thomasi United States Connecticut Court of Appeals May 15, 2018 ... ... Keller, Prescott and Bishop, Js. BISHOP, J. 181 Conn.App. 824 These appeals arise from the dissolution of marriage between the plaintiff, Tracy M. Thomasi, 1 and the defendant, Edward J. Thomasi, Sr. In AC 39452, the plaintiff appeals from the postdissolution ... See generally In re Marriage of Rockwell , 141 Wash. App. 235, 253–54, 170 P.3d 572 (2007), review denied, 163 Wash. 2d 1055, 187 P.3d 752 (2008) ; In reChavez , 80 Wash. App. 432, 436, ... ... Get Started for Free 12 books & journal articles §28.05 Judicial Establishment of Child Support United States Washington State Bar Association Washington Family Law Deskbook (WSBA) Chapter 28 Child Support Invalid date ...and we must vacate the trial court's decree because it committed a manifest abuse of discretion. Rockwell, 141 Wn. App. at 243, 170 P.3d 572 . Marriage of Urbana, 147 Wn. App. at 12-13. [9] Adjustment Clauses Setting support as a sum certain, as required by RCW 26.23.050(5)(d), means that an...... Table of Cases United States Washington State Bar Association Washington Family Law Deskbook (WSBA) Table of Cases Invalid date ...v. Transamerica Ins. Co., 368 F.2d 37 (10th Cir. 1966) . . . . . . . . . . . . . . . . . . . . . . 22.08[2] Rockwell, In re Marriage of, 141 Wn. App. 235 , 170 P.3d 572 (2007) . . . . 27.03; 28.05[8]; 30.03[2]; 31.02[3]; 32.02[5]; 32.04[3]; 65.02[2]; 65.04[3] Rockwell, In re Marriage of, 168...... § 3.02 PARTICULAR ASSETS United States Washington State Bar Association Washington Community Property Deskbook (WSBA) (2023 Ed.) Chapter 3 Character of Ownership of Property Invalid date ...most likely to be used with a "defined benefit" plan, which is earned purely on the basis of time employed. In re Marriage of Rockwell, 141 Wn. App. 235 , 170 P.3d 572 (2007), review denied, 163 Wn.2d 1055 (2008); In re Marriage of Greene, 97 Wn. App. 708, 713, 986 P.2d 144 (1999); Chavez v....... § 5.06 SUSPENSION AND DISSOLUTION OF THE MARRIAGE OR THE REGISTERED DOMESTIC PARTNERSHIP BY THE PARTIES United States Washington State Bar Association Washington Community Property Deskbook (WSBA) (2023 Ed.) Chapter 5 Transactions and Agreements Between Married Persons, Registered Domestic Partners, and Committed Intimate Partners Invalid date ...court's objective is to place the parties in roughly equal financial positions for the rest of their lives." In re Marriage of Rockwell, 141 Wn. App. 235 , 243, 170 P.3d 572 (2007), review denied, 163 Wn.2d 1055 (2008). The Rockwell court affirmed that this objective of "rough equality" in l...... 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    Hall Approved +Free Access to American Case Law
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    In Re Marriage of Rockwell

    In Re Marriage of Rockwell
    Court of Appeals of Washington · Decided September 7, 2010 · Appelwick
    238 P.3d 1184 +(Pacific Reporter, Third Series)

    In Re Marriage of Rockwell

    Opinion

    238 P.3d 1184 (2010)

    In the Matter of the MARRIAGE OF Carmen P. ROCKWELL, Respondent, and
    Peter G. Rockwell, Appellant.

    No. 63079-2-I.

    Court of Appeals of Washington, Division 1.

    July 6, 2010.
    Publication Ordered September 7, 2010.

    *1185 Gregory Mann Miller, Jason W. Anderson, Carney Badley Spellman, Seattle, WA, Mary L. Hammerly, Attorney at Law, Issaquah, WA, for Appellant.

    Catherine W. Smith, Valerie A. Villacin, Edwards Sieh Smith & Goodfriend PS, Cynthia B. Whitaker, Law Offices of Cynthia B. Whitaker, Seattle, WA, for Respondent.

    APPELWICK, J.

    ¶ 1 Peter Rockwell appeals the division of marital property, arguing it is not just and equitable. The parties argued below that the trial court was mandated by our earlier opinion to follow one of two choices on remand; it was not. We cannot ascertain from the record whether the trial court exercised its discretion or felt constrained to choose between the two positions argued. We vacate the judgment and remand.

    FACTS

    ¶ 2 Peter and Carmen Rockwell were married from 1978 until 2004, a total of 26 years. In re Marriage of Rockwell, 141 Wash.App. 235, 239, 170 P.3d 572 (2007), review denied, 163 Wash.2d 1055, 187 P.3d 752 (2008). The facts underlying the first appeal of the dissolution of the community are set out in our first opinion and need not be repeated here. In response to a challenge to the division of property, we affirmed the trial court's overall 60/40 division of the property in favor of Carmen as just and equitable. Id. at 255, 170 P.3d 572. However, in response to the cross-appeal, we held the trial court abused its discretion when it used the subtraction method to calculate the separate property portion of Carmen's pension. Id. at 253-54, 170 P.3d 572. We held that the time rule method applied. Id. at 254, 170 P.3d 572. We remanded for distribution according to the new calculation. Id.

    ¶ 3 On remand, the trial court applied the time rule method to the pension, awarded the separate portion of the pension to Carmen, and divided the community property portion of the pension 60/40. It did not otherwise change the community property division originally *1186 made. This resulted in an overall division closer to 70/30 in Carmen's favor. The trial court entered judgment in favor of Carmen in the amount of $77,958.42, which included reimbursements of overpayments from the pension, prejudgment interest, attorney fees, and expenses and costs. Peter timely filed a notice of appeal.

    DISCUSSION

    ¶ 4 We review an order distributing property for an abuse of discretion. In re Marriage of Kraft, 119 Wash.2d 438, 450, 832 P.2d 871 (1992). In a dissolution action, all property, community and separate, is before the court for distribution. In re Marriage of Stachofsky, 90 Wash.App. 135, 142, 951 P.2d 346 (1998). The relevant factors in determining a just and equitable distribution of property are provided by RCW 26.09.080. In dissolving a marriage of 25 years or more, the trial court must put the parties in roughly equal financial positions for the rest of their lives. Rockwell, 141 Wash.App. at 243, 170 P.3d 572.

    ¶ 5 In this appeal, the disagreement on whether the property distribution is fair and equitable stems from the parties' disagreement over this court's instructions in the first appeal. On remand, the parties appear to have agreed that Carmen should receive the separate property portion of her pension. Carmen argued the Court of Appeals decision required the trial court to award her 60 percent of the 62 percent community property portion of the pension and all of her separate property. Id. at 253, 170 P.3d 572. Peter argued that the Court of Appeals decision required the trial court to divide the recharacterized pension so that the overall 60/40 division of assets would be maintained. The trial court apparently accepted that it had to choose between the two options presented by the parties. The court explained:

    And where I am having some problems with [Carmen's] argument is starting at the last paragraph on page 20, where the court of appeals quotes me as having concluded, quote, "The basics of the ruling are a 60/40 split, based on the difference in age, earning capacity, physical condition, and that Peter has the ability to earn income and save for retirements in the future." And then the last clause on the second from the bottom line is, "We conclude there was no abuse of discretion in making this final distribution."

    The court then stated, "All I'm saying is that in my view, whatever I do, it still has to end up 60/40, however the math gets worked." The court continued, "So in terms of recharacterizing the pension, if it doesn't come out 60/40, I have, in fact, changed what the court of appeals affirmed." The court awarded Carmen the separate property portion of the pension and 60 percent of the community property portion of the pension and did not change its prior division of the rest of the community property. This maintained the 60/40 community property split, but resulted in an overall division of 70/30 in Carmen's favor.

    ¶ 6 We "reverse[d] the trial court's characterization of Carmen's federal pension and affirm[ed] on the other issues appealed. We remand[ed] for further proceedings consistent with [that] opinion." Rockwell, 141 Wash.App. at 255, 170 P.3d 572. The court regrets that the earlier opinion created confusion and provided the parties with a clear basis to argue the positions taken on remand. However, the language "we remand for `further proceedings'" signals this court's expectation that the trial court will exercise its discretion to decide any issue necessary to resolve the case. State v. Schwab, 134 Wash. App. 635, 645, 141 P.3d 658 (2006) (quoting Roberson v. Perez, 156 Wash.2d 33, 42, 123 P.3d 844 (2005)), aff'd by, 163 Wash.2d 664, 185 P.3d 1151 (2008). The opinion did not mandate that the trial court preserve the 60/40 overall division initially ordered. We did not intend to bind the trial court on remand to only the two alternatives argued by counsel. We intended that the trial court exercise its discretion on remand. We cannot ascertain from this record that it did so, and for this reason, we vacate the judgment and remand for further proceedings.

    ¶ 7 Peter argues that the trial court improperly awarded prejudgment interest on the amounts overpaid under the earlier split of the pension payments. Because this issue is likely to recur on remand, we will address it. A prevailing party is generally entitled to prejudgment interest, provided the damages *1187 are liquidated. Lakes v. von der Mehden, 117 Wash.App. 212, 214, 70 P.3d 154 (2003). The interest is awardable when the amount claimed is liquidated. Id. at 217, 70 P.3d 154. A claim is liquidated if data in the evidence makes it possible to compute the amount with exactness, without reliance on opinion or discretion. Id. Interest is not a penalty but compensation for the loss of use of those funds. Jones v. Best, 134 Wash.2d 232, 242, 950 P.2d 1 (1998). A dissolution is an equitable proceeding in which the trial court has broad discretion to fashion remedies. See RCW 26.09.080; In re Marriage of White, 105 Wash.App. 545, 549, 20 P.3d 481 (2001). We see no reason to hold that prejudgment interest is unavailable to the trial court as one of the tools in fashioning an equitable remedy for the loss of use of a liquidated sum.

    ¶ 8 Both parties request fees on appeal, pursuant to RCW 26.09.140 ("Upon any appeal, the appellate court may, in its discretion, order a party to pay for the cost to the other party of maintaining the appeal and attorney's fees in addition to statutory costs."). We decline to award fees on appeal to either party.

    ¶ 9 We vacate the judgment and remand for further proceedings.

    WE CONCUR: DWYER, C.J., and GROSSE, J.

    Case-law data current through December 31, 2025. Source: CourtListener bulk data.

    ↑ + \ No newline at end of file diff --git a/.research/rockwell2010.txt b/.research/rockwell2010.txt new file mode 100644 index 0000000..5e81202 --- /dev/null +++ b/.research/rockwell2010.txt @@ -0,0 +1 @@ +In Re Marriage of Rockwell, 238 P.3d 1184 (Court of Appeals of Washington 2010) | HallApproved.com Hall Approved Free Access to American Case Law Statutes Free Legal Archive / Washington / Cases / Court of Appeals of Washington / 2010 / Court of Appeals of Washington, 2010 Copy citation Free Legal Archive / Washington / Cases / Court of Appeals of Washington / 2010 / In Re Marriage of Rockwell In Re Marriage of Rockwell Court of Appeals of Washington · Decided September 7, 2010 · Appelwick 238 P.3d 1184 (Pacific Reporter, Third Series) In Re Marriage of Rockwell Opinion 238 P.3d 1184 (2010) In the Matter of the MARRIAGE OF Carmen P. ROCKWELL, Respondent, and Peter G. Rockwell, Appellant. No. 63079-2-I. Court of Appeals of Washington, Division 1. July 6, 2010. Publication Ordered September 7, 2010. *1185 Gregory Mann Miller, Jason W. Anderson, Carney Badley Spellman, Seattle, WA, Mary L. Hammerly, Attorney at Law, Issaquah, WA, for Appellant. Catherine W. Smith, Valerie A. Villacin, Edwards Sieh Smith & Goodfriend PS, Cynthia B. Whitaker, Law Offices of Cynthia B. Whitaker, Seattle, WA, for Respondent. APPELWICK, J. ¶ 1 Peter Rockwell appeals the division of marital property, arguing it is not just and equitable. The parties argued below that the trial court was mandated by our earlier opinion to follow one of two choices on remand; it was not. We cannot ascertain from the record whether the trial court exercised its discretion or felt constrained to choose between the two positions argued. We vacate the judgment and remand. FACTS ¶ 2 Peter and Carmen Rockwell were married from 1978 until 2004, a total of 26 years. In re Marriage of Rockwell, 141 Wash.App. 235, 239 , 170 P.3d 572 (2007), review denied, 163 Wash.2d 1055 , 187 P.3d 752 (2008). The facts underlying the first appeal of the dissolution of the community are set out in our first opinion and need not be repeated here. In response to a challenge to the division of property, we affirmed the trial court's overall 60/40 division of the property in favor of Carmen as just and equitable. Id. at 255, 170 P.3d 572 . However, in response to the cross-appeal, we held the trial court abused its discretion when it used the subtraction method to calculate the separate property portion of Carmen's pension. Id. at 253-54, 170 P.3d 572 . We held that the time rule method applied. Id. at 254, 170 P.3d 572 . We remanded for distribution according to the new calculation. Id. ¶ 3 On remand, the trial court applied the time rule method to the pension, awarded the separate portion of the pension to Carmen, and divided the community property portion of the pension 60/40. It did not otherwise change the community property division originally *1186 made. This resulted in an overall division closer to 70/30 in Carmen's favor. The trial court entered judgment in favor of Carmen in the amount of $77,958.42, which included reimbursements of overpayments from the pension, prejudgment interest, attorney fees, and expenses and costs. Peter timely filed a notice of appeal. DISCUSSION ¶ 4 We review an order distributing property for an abuse of discretion. In re Marriage of Kraft, 119 Wash.2d 438, 450 , 832 P.2d 871 (1992). In a dissolution action, all property, community and separate, is before the court for distribution. In re Marriage of Stachofsky, 90 Wash.App. 135, 142 , 951 P.2d 346 (1998). The relevant factors in determining a just and equitable distribution of property are provided by RCW 26.09.080. In dissolving a marriage of 25 years or more, the trial court must put the parties in roughly equal financial positions for the rest of their lives. Rockwell, 141 Wash.App. at 243 , 170 P.3d 572 . ¶ 5 In this appeal, the disagreement on whether the property distribution is fair and equitable stems from the parties' disagreement over this court's instructions in the first appeal. On remand, the parties appear to have agreed that Carmen should receive the separate property portion of her pension. Carmen argued the Court of Appeals decision required the trial court to award her 60 percent of the 62 percent community property portion of the pension and all of her separate property. Id. at 253, 170 P.3d 572 . Peter argued that the Court of Appeals decision required the trial court to divide the recharacterized pension so that the overall 60/40 division of assets would be maintained. The trial court apparently accepted that it had to choose between the two options presented by the parties. The court explained: And where I am having some problems with [Carmen's] argument is starting at the last paragraph on page 20, where the court of appeals quotes me as having concluded, quote, "The basics of the ruling are a 60/40 split, based on the difference in age, earning capacity, physical condition, and that Peter has the ability to earn income and save for retirements in the future." And then the last clause on the second from the bottom line is, "We conclude there was no abuse of discretion in making this final distribution." The court then stated, "All I'm saying is that in my view, whatever I do, it still has to end up 60/40, however the math gets worked." The court continued, "So in terms of recharacterizing the pension, if it doesn't come out 60/40, I have, in fact, changed what the court of appeals affirmed." The court awarded Carmen the separate property portion of the pension and 60 percent of the community property portion of the pension and did not change its prior division of the rest of the community property. This maintained the 60/40 community property split, but resulted in an overall division of 70/30 in Carmen's favor. ¶ 6 We "reverse[d] the trial court's characterization of Carmen's federal pension and affirm[ed] on the other issues appealed. We remand[ed] for further proceedings consistent with [that] opinion." Rockwell, 141 Wash.App. at 255 , 170 P.3d 572 . The court regrets that the earlier opinion created confusion and provided the parties with a clear basis to argue the positions taken on remand. However, the language "we remand for `further proceedings'" signals this court's expectation that the trial court will exercise its discretion to decide any issue necessary to resolve the case. State v. Schwab, 134 Wash. App. 635, 645 , 141 P.3d 658 (2006) (quoting Roberson v. Perez, 156 Wash.2d 33, 42 , 123 P.3d 844 (2005)), aff'd by, 163 Wash.2d 664 , 185 P.3d 1151 (2008). The opinion did not mandate that the trial court preserve the 60/40 overall division initially ordered. We did not intend to bind the trial court on remand to only the two alternatives argued by counsel. We intended that the trial court exercise its discretion on remand. We cannot ascertain from this record that it did so, and for this reason, we vacate the judgment and remand for further proceedings. ¶ 7 Peter argues that the trial court improperly awarded prejudgment interest on the amounts overpaid under the earlier split of the pension payments. Because this issue is likely to recur on remand, we will address it. A prevailing party is generally entitled to prejudgment interest, provided the damages *1187 are liquidated. Lakes v. von der Mehden, 117 Wash.App. 212, 214 , 70 P.3d 154 (2003). The interest is awardable when the amount claimed is liquidated. Id. at 217 , 70 P.3d 154 . A claim is liquidated if data in the evidence makes it possible to compute the amount with exactness, without reliance on opinion or discretion. Id. Interest is not a penalty but compensation for the loss of use of those funds. Jones v. Best, 134 Wash.2d 232, 242 , 950 P.2d 1 (1998). A dissolution is an equitable proceeding in which the trial court has broad discretion to fashion remedies. See RCW 26.09.080; In re Marriage of White, 105 Wash.App. 545, 549 , 20 P.3d 481 (2001). We see no reason to hold that prejudgment interest is unavailable to the trial court as one of the tools in fashioning an equitable remedy for the loss of use of a liquidated sum. ¶ 8 Both parties request fees on appeal, pursuant to RCW 26.09.140 ("Upon any appeal, the appellate court may, in its discretion, order a party to pay for the cost to the other party of maintaining the appeal and attorney's fees in addition to statutory costs."). We decline to award fees on appeal to either party. ¶ 9 We vacate the judgment and remand for further proceedings. WE CONCUR: DWYER, C.J., and GROSSE, J. Case-law data current through December 31, 2025. Source: CourtListener bulk data . A public interest project of Aaron Hall, Attorney at Law © 2026 About Federal Minnesota California New York Texas Terms Data from CourtListener / Free Law Project ↑ \ No newline at end of file diff --git a/.research/sedlock.html b/.research/sedlock.html new file mode 100644 index 0000000..1bf78b4 --- /dev/null +++ b/.research/sedlock.html @@ -0,0 +1 @@ +Just a moment...
    \ No newline at end of file diff --git a/.research/washburn.html b/.research/washburn.html new file mode 100644 index 0000000..1b33143 --- /dev/null +++ b/.research/washburn.html @@ -0,0 +1,25 @@ +In Re the Marriage of Washburn, 677 P.2d 152 (Wash. 1984) | HallApproved.com
    Hall Approved +Free Access to American Case Law
    Washington Supreme Court, 1984 +

    In Re the Marriage of Washburn

    In Re the Marriage of Washburn
    Washington Supreme Court · Decided February 16, 1984 · Dimmick, Rosellini, Williams, Stafford, Utter, Brachtenbach, Dolliver, Dore, Pearson
    677 P.2d 152; 101 Wash. 2d 168; 1984 Wash. LEXIS 1508 +(Pacific Reporter, Second Series)

    In Re the Marriage of Washburn

    Opinion of the Court

    Dimmick, J.

    When one spouse supports the other through professional school in the mutual expectation that the community will enjoy the financial benefit flowing from the resulting professional degree, but the marriage is dissolved before that benefit can be realized, should the supporting spouse be compensated? Our answer is yes. The contribution of the supporting spouse to the attainment of a professional degree by the student spouse is a factor to be considered in dividing property and liabilities pursuant to RCW 26.09.080, or in awarding maintenance pursuant to RCW 26.09.090. The Washburn court failed to consider Mrs. Washburn's contribution to her husband's education in any respect. We thus reverse and remand for consideration of the appropriate compensation due Mrs. Washburn. The Gillette court did value Mrs. Gillette's contribution to Mr. Gillette's education and supplemented its property division with a lump-sum award of $19,000, to be paid over time. We affirm this award.

    I

    A. Washburn. The parties were married in 1971 while they were juniors at the University of Idaho. Upon their graduation in 1973, both parties worked. In the fall of 1974 they moved to Pullman, Washington, so that Mr. Wash-burn could attend veterinary school at Washington State University. From the fall of 1974 until February 1978 Mr. Washburn attended classes and held summer and part-time employment. During this same period Mrs. Washburn *171worked full time. The parties then moved to Kentucky to allow Mr. Washburn to participate in an internship. Mr. Washburn received his degree in June 1978.

    Upon Mr. Washburn's graduation the parties moved to Michigan where Mr. Washburn served an internship. Mrs. Washburn worked full time until their child was born in April 1979. In July 1979 the parties returned to Snohomish, where Mr. Washburn began practice as a veterinarian. They separated in January 1981 and a decree of dissolution was entered in June.

    The trial court found that the parties' family home had been sold during the separation and the $4,400 proceeds equally divided. It awarded the remaining community property to the party in possession thereof (approximately $3,500 to Mrs. Washburn and $5,700 to Mr. Washburn) and required Mr. Washburn to pay all community debts, including educational loans. The trial court denied Mrs. Washburn's request for maintenance. The court also declined to characterize Mr. Washburn's degree as property, and refused to admit expert testimony which would have established the value of the degree through comparison of Mr. Washburn's earning potentials with and without it. Finally, it concluded that a judgment in favor of one spouse as against the other as compensation for contribution toward the cost of an education was impermissible.

    Mrs. Washburn appeals that portion of the court's conclusion of law relating to Mr. Washburn's degree.

    B. Gillette. The parties were married in 1968. In 1970 they both contributed equally to the purchase of a ranch. The ranch operation, however, failed. In 1974 the parties agreed that Mr. Gillette should obtain a degree in veterinary medicine. The trial court, in an unchallenged finding of fact, found that at this time the parties both anticipated they would share equally in the expected increased earning capacity of Mr. Gillette and agreed to undertake the effort. The court in addition found that Mr. Gillette promised Mrs. Gillette that if she would support him during his years in school, she would never have to work again.

    *172Mr. Gillette obtained his undergraduate degree in biology in 1978 from Eastern Oregon State College and was accepted into the veterinary college at Washington State University. The parties separated in October 1981. During Mr. Gillette's schooling and while the parties were together, Mrs. Gillette worked full time, contributing her income and money from a personal injury settlement. She turned down offers of job promotions so that she could move with her husband to Washington State University. Mr. Gillette worked part time, and also received gifts from his father and disability payments. Mr. Gillette obtained his degree in veterinary medicine in 1982. A decree of dissolution was entered in March 1983.

    The trial court found that the parties' lifestyle had been modest and their net worth diminished during the time Mr. Gillette had attended school. It affirmed the parties' own division of their community property (approximately $13,295 to Mrs. Gillette and $7,540 to Mr. Gillette). It charged Mr. Gillette with the educational loans incurred prior to and after separation. Mrs. Gillette agreed to pay past taxes.

    The trial court concluded that neither the professional degree nor the increased earning capacity resulting from that degree were property subject to division. However, it awarded Mrs. Gillette a judgment of $19,000 as an "equitable right to restitution," which it calculated as follows:

    During the 7%-year period the Petitioner was in school, the Respondent contributed an excess of $24,000.00 to the community. It is reasonable to assume that she consumed one-half that amount. During that time she lived a more spartan life than would have otherwise been necessary. There is no source of funds at present from which to order immediate repayment. Inflation had a very dramatic effect upon the value of the dollar during the period of the Petitioner's schooling. Petitioner has therefore benefited from the $12,000.00 excess contribution. The wife is receiving property and liabilities with a net value of $8,800.00 more than one-half of the parties' net worth and that sum is therefore subtracted from *173$12,000.00, leaving a $3,200.00 deficit. An additional sum of $12,000.00 should be added to reimburse the wife for TVi years of reduced living standards and a reduced opportunity to accumulate property. This is based upon the theory that if the Petitioner had worked full-time instead of going to school he would have at least equalled Respondent's earnings, and the Respondent would have benefited from one-half of that increased earning ability. In addition, the wife would have had better working conditions and security had she taken the promotions offered at the time. The $12,000.00 added to $3,200.00 equals $15,200.00. To adjust for inflation, the figure should be increased by 25%, which adds $3,800.00 for a total of $19,000.00.

    Conclusion of law 4. Clerk's Papers, at 75-76.

    The trial court also found Mrs. Gillette was entitled to maintenance in the amount of $1 per year.

    Mr. Gillette appeals from the portion of the decree requiring him to pay $19,000 and maintenance. Mrs. Gillette cross-appeals contending Mr. Gillette's increased earning capacity resulting from the education is property which should be valued and divided.

    II

    The cases at bar are representative of a situation which is so familiar as to be almost a cliche. A husband and wife make the mutual decision that one of them will support the other while he or she obtains a professional degree. The educational years will be lean ones for the family not only because of heavy educational expenses, but also because the student spouse will be able to earn little or nothing. Moreover, the supporting spouse may be called upon to postpone his or her own education or forgo promotions and other valuable career opportunities in order to find a job near the student spouse's school. These sacrifices are made in the mutual expectation that the family will enjoy a higher standard of living once the degree is obtained. But dissolution of the marriage intervenes. Because the family spent most of its financial resources on the degree, there may be few or no assets to be distributed. The student spouse has *174the degree and the increased earning potential that it represents, while the supporting spouse has only a dissolution decree.

    A

    Other courts have responded to this all too common situation in a variety of ways.

    A few appellate courts adopt the view that the professional degree (or the enhanced earning potential which it represents) is property which must be valued and distributed upon dissolution of the marriage. These courts differ in their valuation of the degree or earning potential. See Woodworth v. Woodworth, 126 Mich. App. 258, 337 N.W.2d 332 (1983); In re Marriage of Horstmann, 263 N.W.2d 885 (Iowa 1978).1

    Another line of cases holds that, although a professional degree is not property, the supporting spouse is entitled to restitution of the money he or she spent toward the attainment of the degree, in order to prevent unjust enrichment of the student spouse. The formula used to determine the amount of restitution varies from court to court. See Hubbard v. Hubbard, 603 P.2d 747 (Okla. 1979); DeLa Rosa v. DeLa Rosa, 309 N.W.2d 755 (Minn. 1981).

    Still other courts find the solution in an award of maintenance to the supporting spouse. One court grants "reimbursement alimony" equal to the amount spent by the supporting spouse toward the education. See Mahoney v. Mahoney, 91 N.J. 488, 453 A.2d 527 (1982). Others recog*175nize the contribution of the supporting spouse as a basis for awarding maintenance, but do not prescribe a formula for determining the amount. See Moss v. Moss, 80 Mich. App. 693, 264 N.W.2d 97, appeal denied, 402 Mich. 946 (1978); Magruder v. Magruder, 190 Neb. 573, 209 N.W.2d 585 (1973); Daniels v. Daniels, 20 Ohio Ops. 2d 458, 185 N.E.2d 773 (Ct. App. 1961); In re Marriage of Lundberg, 107 Wis. 2d 1, 318 N.W.2d 918 (1982).

    Another approach is to consider the supporting spouse's contribution to the attainment of the professional degree when dividing marital assets between the parties. See In re Marriage of McVey, 641 P.2d 300 (Colo. Ct. App. 1981); Vaclav v. Vaclav, 96 Mich. App. 584, 293 N.W.2d 613 (1980); In re Marriage of Vanet, 544 S.W.2d 236 (Mo. Ct. App. 1976).

    Finally, some courts simply deny any recovery to the supporting spouse. See Wisner v. Wisner, 129 Ariz. 333, 631 P.2d 115 (Ct. App. 1981); In re Marriage of Sullivan, 134 Cal. App. 3d 484, 184 Cal. Rptr. 796 (1982); In re Marriage of Graham, 194 Colo. 429, 574 P.2d 75 (1978); In re Marriage of Goldstein, 97 Ill. App. 3d 1023, 423 N.E.2d 1201 (1981); Wilcox v. Wilcox, 173 Ind. App. 661, 365 N.E.2d 792 (1977); Severs v. Severs, 426 So. 2d 992 (Fla. Dist. Ct. App. 1983); Muckleroy v. Muckleroy, 84 N.M. 14, 498 P.2d 1357 (1972); Lesman v. Lesman, 88 A.D.2d 153, 452 N.Y.S.2d 935 (1982); Frausto v. Frausto, 611 S.W.2d 656 (Tex. Civ. App. 1980). Generally, these courts deny recovery because they cannot find a legal label for the requested award which seems to fit. Designation of the degree as "property" which may be valued and equitably divided is rejected because the degree, which cannot be sold, assigned or inherited, lacks the traditional attributes of property. See Graham, at 432. Unjust enrichment, which would place a value on the supporting spouse's contribution, is rejected as inappropriate in the context of marriage, which is "more than an economic undertaking." Lesman, at 159. Maintenance is rejected because the supporting spouse is capable of self-support. Wilcox, at 665. The ability to *176consider the supporting spouse's contribution in dividing marital assets is acknowledged, but proves useless because there are no assets. See Graham, at 433.

    B

    In view of the fact that fault is an impermissible consideration in a dissolution proceeding in this state,2 we are disinclined to compensate the supporting spouse under the theory of unjust enrichment, as was done in Hubbard and DeLa Rosa. Unjust enrichment is a contract implied at law requiring a person to make restitution to the extent he has been unjustly enriched. Not only must the person be enriched, but the enrichment must be unjust. Truckweld Equip. Co. v. Olson, 26 Wn. App. 638, 646, 618 P.2d 1017 (1980). To require trial courts to determine whether the student spouse had been unjustly enriched by the efforts of the supporting spouse would invite the introduction of evidence as to who was at fault in the termination of the marriage before the fruits of the degree could be realized. Nor are we inclined to address at this time the somewhat metaphysical question of whether a professional degree is "property." However, we need not join the ranks of those courts which deny recovery. The liberal provisions of our dissolution of marriage act, codified in RCW 26.09, provide a flexible way for courts to fairly compensate supporting spouses in the state of Washington.

    RCW 26.09.080 governs the distribution of property and liabilities:

    In a proceeding for dissolution of the marriage, legal separation, declaration of invalidity, or in a proceeding for disposition of property following dissolution of the marriage by a court which lacked personal jurisdiction over the absent spouse or lacked jurisdiction to dispose of *177the property, the court shall, without regard to marital misconduct, make such disposition of the property and the liabilities of the parties, either community or separate, as shall appear just and equitable after considering all relevant factors including, but not limited to:
    (1) The nature and extent of the community property;
    (2) The nature and extent of the separate property;
    (3) The duration of the marriage; and
    (4) The economic circumstances of each spouse at the time the division of property is to become effective, including the desirability of awarding the family home or the right to live therein for reasonable periods to a spouse having custody of any children.

    As this provision makes clear, a division of property and liabilities is controlled not by their character as separate or community, but rather by what is just and equitable, taking into account the economic circumstances of the parties. All relevant factors must be considered by the trial court in its attempt to achieve an equitable distribution.

    RCW 26.09.090 controls the awarding of maintenance:

    (1) In a proceeding for dissolution of marriage, legal separation, declaration of invalidity, or in a proceeding for maintenance following dissolution of the marriage by a court which lacked personal jurisdiction over the absent spouse, the court may grant a maintenance order for either spouse. The maintenance order shall be in such amounts and for such periods of time as the court deems just, without regard to marital misconduct, after considering all relevant factors including but not limited to:
    (a) The financial resources of the party seeking maintenance, including separate or community property apportioned to him, and his ability to meet his needs independently, including the extent to which a provision for support of a child living with the party includes a sum for that party as custodian;
    (b) The time necessary to acquire sufficient education or training to enable the party seeking maintenance to find employment appropriate to his skill, interests, style of life, and other attendant circumstances;
    (c) The standard of living established during the marriage;
    (d) The duration of the marriage;
    (e) The age, physical and emotional condition, and *178financial obligations of the spouse seeking maintenance; and
    (f) The ability of the spouse from whom maintenance is sought to meet his needs and financial obligations while meeting those of the spouse seeking maintenance.

    Under this provision, the only limitation placed upon the trial court's ability to award maintenance is that the amount and duration, considering all relevant factors, be just. Additionally, RCW 26.09.170 authorizes the court to continue the maintenance obligation beyond the death of either party or the remarriage of the party receiving maintenance.

    When a person supports a spouse through professional school in the mutual expectation of future financial benefit to the community, but the marriage ends before that benefit can be realized, that circumstance is a "relevant factor" which must be considered in making a fair and equitable division of property and liabilities pursuant to RCW 26.09.080, or a just award of maintenance pursuant to RCW 26.09.090. A professional degree confers high earning potential upon the holder. The student spouse should not walk away with this valuable advantage without compensating the person who helped him or her obtain it.

    We have said that the supporting spouse may be compensated through a division of property and liabilities. In many cases, however, the wealth of the marriage will have been spent toward the cost of the professional degree, leaving few or no assets to divide. Where the assets of the parties are insufficient to permit compensation to be effected entirely through property division, a supplemental award of maintenance is appropriate.

    With respect to maintenance, we recognize that the spouse who is capable of supporting someone through school will in most cases also be capable of supporting him or herself after the marriage is dissolved. However, under the extremely flexible provisions of RCW 26.09.090, a demonstrated capacity of self-support does not automatically preclude an award of maintenance. Indeed, the ability of *179the spouse seeking maintenance to meet his or her needs independently is only one factor to be considered. RCW 26.09.090(l)(a). The duration of the marriage and the standard of living established during the marriage must also be considered, making it clear that maintenance is not just a means of providing bare necessities, but rather a flexible tool by which the parties' standard of living may be equalized for an appropriate period of time. RCW 26.09-.090(l)(c), (d). Moreover, the factors listed in the statute are not exclusive. The trial court may consider the supporting spouse's contribution and exercise its broad discretion to grant maintenance, thereby in effect allowing the supporting spouse to share, temporarily, in the lifestyle which he or she helped the student spouse to attain.3

    In making an equitable property division or awarding maintenance, the trial court exercises broad discretionary powers. Its disposition will not be overturned on appeal absent a showing of manifest abuse of discretion. See Baker v. Baker, 80 Wn.2d 736, 747, 498 P.2d 315 (1972); In re Marriage of Glorfield, 27 Wn. App. 358, 360, 617 P.2d 1051, review denied, 94 Wn.2d 1025 (1980); In re Marriage of Nicholson, 17 Wn. App. 110, 116, 561 P.2d 1116 (1977). We are reluctant to encroach upon this discretion by providing a precise formula prescribing the amount of property to be distributed or maintenance to be awarded to the supporting spouse.

    Instead, we direct the trial court to consider the following factors, among others, in determining the proper amount of compensation for the supporting spouse:

    1. The amount of community funds expended for direct *180educational costs, including tuition, fees, books, and supplies. We do not include living expenses incurred by the student spouse as a factor because those expenses would have existed regardless of whether the student spouse pursued a professional education.

    2. The amount which the community would have earned had the efforts of the student spouse not been directed toward his or her studies. By including this factor, we do not imply that parties to a marriage have a general duty to the community to realize their full economic potential. However, when the parties to a marriage make the joint decision that one spouse should obtain a professional degree or license, the community sacrifices not only the funds spent for direct educational or training costs, but also the earnings of the student spouse, if he or she would otherwise have been working. These sacrifices were made in the expectation that the community would receive financial benefit in the form of increased future earnings. When this expectation is frustrated by dissolution of the marriage, it would be inconsistent to permit the trial court to compensate the supporting spouse for the funds spent, but not the funds forgone.

    3. Any educational or career opportunities which the supporting spouse gave up in order to obtain sufficiently lucrative employment, or to move to the city where the student spouse wished to attend school.

    4. The future earning prospects of each spouse, including the earning potential of the student spouse with the professional degree.

    Factors 1 and 2 reflect funds sacrificed by the community in order to obtain the education or training; accordingly, the supporting spouse should be awarded no more than his or her one-half interest therein. The trial court may take the effect of inflation during the educational years into account. Factor 3 is included to permit the trial court to adjust the property division or maintenance award as appears just and equitable, in light of the opportunities *181forfeited by the supporting spouse.4 Factor 4 simply applies to the present context the long-standing rule that the economic condition in which a dissolution decree leaves the parties is a paramount concern in determining issues of property division and maintenance. See DeRuwe v. DeRuwe, 72 Wn.2d 404, 408, 433 P.2d 209 (1967); In re Marriage of Dessauer, 97 Wn.2d 831, 839, 650 P.2d 1099 (1982).

    We point out that where a marriage endures for some time after the professional degree is obtained, the supporting spouse may already have benefited financially from the student spouse's increased earning capacity to an extent that would make extra compensation inappropriate. For example, he or she may have enjoyed a high standard of living for several years. Or perhaps the professional degree made possible the accumulation of substantial community assets which may be equitably divided. However, our attention today is centered on the more difficult case of the marriage that is dissolved before the supporting spouse has realized a return on his or her investment in family prosperity.

    Some might object that by recognizing the supporting spouse's right to compensation, we are treating marriage as a commercial enterprise. That is not our intent nor the result of this decision. Rather, as was well stated by the court in Mahoney v. Mahoney, 91 N.J. 488, 500, 453 A.2d 527 (1982):

    This Court does not support reimbursement between former spouses in alimony proceedings as a general principle. Marriage is not a business arrangement in which the parties keep track of debits and credits, their accounts to be settled upon divorce. Rather, as we have said, "marriage is a shared enterprise, a joint undertaking ... in many ways it is akin to a partnership." But every *182joint undertaking has its bounds of fairness. Where a partner to marriage takes the benefits of his spouse's support in obtaining a professional degree or license with the understanding that future benefits will accrue and inure to both of them, and the marriage is then terminated without the supported spouse giving anything in return, an unfairness has occurred that calls for a remedy.

    (Citations omitted.)

    Turning to the cases before us today, we note that Mrs. Gillette supported her husband through undergraduate and veterinary school in the mutual expectation that they would both share in the increased earnings which the veterinary degree would produce. Indeed, Mr. Gillette promised his wife that once he received his degree, she would never have to work again. These expectations were shattered when the parties separated only months before Mr. Gillette received his veterinary degree.

    The parties agreed upon a division of community assets, leaving the trial court little opportunity to compensate Mrs. Gillette entirely through property division. To supplement the property division, the court awarded Mrs. Gillette $19,000 as an "equitable right to restitution," based upon her contribution to the attainment of the veterinary degree. The court made this lump-sum award payable over time, thereby reducing the burden on Mr. Gillette.

    The trial court labeled its $19,000 award "restitution." However, because the award will be paid in installments, thereby equalizing the parties' standard of living for a limited time, it is in effect an award of lump-sum maintenance. Our concern is not the particular label applied to this award, but rather its fairness as determined by those factors set out in RCW 26.09.090. See In re Marriage of Hadley, 88 Wn.2d 649, 658, 565 P.2d 790 (1977).

    The trial court calculated the amount of its award to Mrs. Gillette without the benefit of the four factors set forth as guidelines herein. However, RCW 26.09.090 places emphasis on the justness of an award, not its method of calculation. Here, Mrs. Gillette supported her husband *183through IV2 years of school. She turned down offers of job promotions to follow him to Washington State University. Under these circumstances, we cannot say that the trial court's award of $19,000 was a manifest abuse of discretion. See In re Marriage of Nicholson, 17 Wn. App. 110, 561 P.2d 1116 (1977).

    Because the $19,000 award is in effect maintenance, the trial court's order requiring Mr. Gillette to pay maintenance in the amount of $1 per year is unnecessary and is reversed. We affirm, however, the portion of that same order which provides that the award shall not terminate upon Mrs. Gillette's remarriage or death, so that her right to receive the full $19,000 may be preserved.

    We turn next to the Washburn case. Mrs. Washburn worked full time to support Mr. Washburn while he attended veterinary school. Less than 2 years after Mr. Washburn began practice as a veterinarian, the marriage was dissolved. Nevertheless, the trial judge concluded he was unable to compensate Mrs. Washburn for her contribution to her husband's education, stating:

    I don't believe that I am prepared, nor am I convinced I'd be authorized to make, enter a judgment in favor of one spouse as against the other as compensation, and that's really what we are speaking of, compensation for the broken, lost, destroyed hopes and aspirations that the parties had, either when they got married or during the early years of their marriage.
    In this case there is just nothing, no asset to divide. When and if our Supreme Court comes to the point of holding that I can make a division or can in effect make a division of future earning potential, separate and apart from any physical or tangible asset of the parties, maybe we will have a new approach to the dissolution, I do not feel prepared to innovate that type of approach.

    Clerk's Papers, at 29-30 (oral ruling of the court).

    Under our opinion today, Mrs. Washburn may be entitled to an award as compensation for her contribution to her husband's education. Such compensation may be effected through property division, maintenance, or a com*184bination of both. Although Mrs. Washburn did not appeal from the trial court's denial of maintenance, she did appeal the broader issue of whether she was entitled to a judgment as compensation for her contribution toward the cost of her husband's education. We reverse the Washburn court's conclusion of law that a judgment as compensation for contribution toward the cost of an education is impermissible, and remand for consideration of the compensation due Mrs. Washburn.

    Gillette is affirmed. Washburn is reversed in relevant part and remanded.

    Williams, C.J., and Stafford, Utter, Brachtenbach, Dolliver, Dore, and Pearson, JJ., concur. +

    Inman v. Inman, 578 S.W.2d 266 (Ky. Ct. App. 1979), modified, 8 Fam. L. Rep. (BNA) 2329 (Ky. Ct. App. Mar. 12, 1982), rev'd, 648 S.W.2d 847 (Ky. 1982) is often cited as support for the proposition that a professional degree is marital property in which the supporting spouse has an interest. The authority of the original Inman decision is questionable in light of the later decision in the same case by the Kentucky Supreme Court. The Kentucky Supreme Court stated in dicta that an educational degree received by one spouse while the other spouse contributes financially to the cost of obtaining the degree is not, upon dissolution of the marriage, marital property. The court did, however, recognize the need to fairly compensate the supporting spouse when the marriage ends before the family realizes the expected benefits of the degree. Inman v. Inman, 648 S.W.2d 847, 852 (Ky. 1982). +

    The dissolution of marriage act of 1973 eliminated fault as a relevant consideration in a dissolution proceeding. Under RCW 26.09.030, the sole basis for dissolution of a marriage is that it is irretrievably broken. RCW 26.09.080 and RCW 26.09.090 further provide that marital misconduct is not to be considered by the court in distributing the property and liabilities of the parties, or awarding maintenance. +

    We wish to emphasize that by permitting the supporting spouse to be compensated with an award of maintenance, we are not subjecting the student spouse to some form of involuntary servitude by requiring him or her to work at the chosen profession against his or her will. The ability of the student spouse to pay maintenance is a relevant factor which must be considered in making an award to the supporting spouse. RCW 26.09.090(1) (f). If the student spouse permanently abandons his or her profession, and his or her ability to pay is substantially impaired as a result, this change of circumstances might justify a modification of the maintenance awarded to the supporting spouse. RCW 26.09.170. +

    Another solution available to trial courts in similar cases which was not sought by either Mrs. Washburn or Mrs. Gillette is to allow the supporting spouse to obtain an equal educational opportunity at the student spouse's expense. See Childers v. Childers, 15 Wn. App. 792, 552 P.2d 83 (1976), aff'd in relevant part, 89 Wn.2d 592, 575 P.2d 201 (1978).

    Dissenting Opinion

    Rosellini, J.

    (dissenting) — This case involves the twin issues of characterization and valuation of a spouse's professional education. The majority declines to address whether the professional degree should be characterized as property, and simply holds that the expectation of future financial benefit derived from supporting a spouse through professional school is a relevant "factor" which must be considered in making a just and equitable division of property and liabilities or a just maintenance award. While I am in general agreement with this holding, I would characterize this interest as a marital asset in the context of increased earning capacity subject to distribution.

    The majority's holding on the issue of valuation/recovery is limited to an award to the supporting spouse in the form of reimbursement and/or rehabilitative maintenance or property distribution. I do not agree that such an award is a just and equitable distribution of the assets of the community. I would hold that the value of the educational degree is measured by the increased earning capacity inherent in the particular education and as such is subject to a just and equitable distribution.

    I

    The dissolution of marriage act, RCW 26.09, provides a *185flexible manner of determining what are the assets of the community subject to distribution and includes the respective earning capacities of the parties.

    RCW 26.09.080 reads in part:

    In a proceeding for dissolution of the marriage, legal separation, . . . the court shall, without regard to marital misconduct, make such disposition of the property and the liabilities of the parties, either community or separate, as shall appear just and equitable after considering all relevant factors including, but not limited to:
    (1) The nature and extent of the community property;
    (2) The nature and extent of the separate property;
    (3) The duration of the marriage; and
    (4) The economic circumstances of each spouse at the time the division of property is to become effective, including the desirability of awarding the family home or the right to live therein for reasonable periods to a spouse having custody of any children.

    In addition to the four subsections in RCW 26.09.080, which include " [t]he economic circumstances of each spouse at the time the division of property is to become effective," the court should also consider the age, health, education and employment history of the parties and their children, and the future earning prospects of all of them in determining a just and equitable division. DeRuwe v. DeRuwe, 72 Wn.2d 404, 408, 433 P.2d 209 (1967); In re Marriage of Rink, 18 Wn. App. 549, 551, 571 P.2d 210 (1977). See also Comment, Property Dispositions in Dissolution Proceedings: The Criteria in Washington, 12 Gonz. L. Rev. 492 (1977); Reike, The Dissolution Act of 1973: From Status to Contract?, 49 Wash. L. Rev. 375, 403-05 (1974).

    Additionally, RCW 26.09.090 sets forth the factors to be considered by a trial court in determining the propriety of a maintenance award. These factors include the financial resources, health and education of the respective parties, the duration of the marriage and the standard of living established therein.

    Support for characterizing the professional education degree as a divisible asset is found in other areas of intan*186gible and speculative property rights considered to be divisible upon dissolution.

    The accounting concept of goodwill, like an advanced professional degree, is by nature an asset with an elusive value. However, this court and the lower appellate courts have held that professional goodwill, although intangible and commonly defined as the expectation of continued public patronage, is a factor which has a value and should be included among the assets distributed upon a marriage dissolution. In re Marriage of Fleege, 91 Wn.2d 324, 588 P.2d 1136 (1979); In re Marriage of Kaplan, 23 Wn. App. 503, 597 P.2d 439 (1979); In re Marriage of Freedman, 35 Wn. App. 49, 665 P.2d 902, review denied, 100 Wn.2d 1019 (1983); In re Marriage of Lukens, 16 Wn. App. 481, 558 P.2d 279 (1976), review denied, 88 Wn.2d 1011 (1977). While the goodwill of a particular professional practice may not be marketable and the determination of its value difficult, it is nonetheless an asset of the community because it has a value to the professional spouse. Fleege, at 326-27; Freedman, at 52. The nonprofessional spouse, having contributed to the building of the professional practice through the provision of services, financial, domestic, or otherwise, has a valuable interest in the goodwill of the professional spouse's practice. The mere fact that goodwill is an amorphous asset and a value cannot be precisely determined is an improper basis for a court's refusal to acknowledge and to consider the existence of the goodwill value when dividing the value of a professional practice between spouses in a marital dissolution proceeding. Fleege, at 327-30; Lukens, at 484.

    Methods of placing a value on professional goodwill vary according to the circumstances of each case. Factors considered when valuing the goodwill of a professional practice include the length of time that the professional spouse has practiced, the comparative success of the spouse's professional practice, the professional spouse's age and health, the past profits of the practice, the fixed resources of the practice, and the physical assets of the practice. Fleege, at 326; *187Lukens, at 484.

    The crucial point for our inquiry is not the means by which goodwill is valued, but that a property interest is found in an intangible.

    The divisibility of pension and retirement benefits of an employed spouse upon dissolution provides another analogy to support the proposition that the professional degree be considered an asset subject to distribution. Even though pension and retirement benefits normally are not mature, but are future interests, contingent future interests, or even expectancies, the benefits may have a value to both spouses that is capable of division as property. See Wilder v. Wilder, 85 Wn.2d 364, 534 P.2d 1355 (1975); DeRevere v. DeRevere, 5 Wn. App. 741, 491 P.2d 249 (1971). See also Foster & Freed, Spousal Rights in Retirement and Pension Benefits, 16 J. Fam. L. 187 (1977-78).

    In a wrongful death or a personal injury action, courts consistently have recognized the need to determine the value of a professional education in order to compensate fully a plaintiff for loss of future income. Damages in a personal injury or wrongful death action are unliquidated; no one fixed mathematical formula is used to decide each case. Rather, each case involves different facts, considerations, and probabilities to which courts cannot attempt to apply a formula. Instead, courts must assume that each situation is unique and recognize that a determination of damages involves some speculation, uncertainty, and arbitrariness. Courts, however, rarely deny a remedy for lost future earning capacity in a personal injury or wrongful death action merely because assessing future earning capacity involves the court in some speculation. We should be equally hesitant to deny relief to a nonstudent spouse who has lost the economic potential of the partial value of the education that she helped to provide. See Peck & Hopkins, Economics and Impaired Earning Capacity in Personal Injury Cases, 44 Wash. L. Rev. 351 (1969).

    A court easily can extend the tort concept of valuation of future earning capacity to a situation in which the support*188ing spouse will lose the economic benefits of the degreed spouse's education upon dissolution of the marriage. The nonstudent spouse will lose the same expectancy as the plaintiff will in the personal injury or wrongful death action. See Comment, The Interest of the Community in a Professional Education, 10 Cal. W. L. Rev. 590 (1974).

    A number of recent cases from sister jurisdictions have held that the supporting spouse is entitled to a distribution of increased earning potential for his or her support of the family while the other spouse obtained an education.

    The leading case cited most often for the proposition that a professional degree is not property is the Colorado Supreme Court decision of Graham v. Graham, 194 Colo. 429, 574 P.2d 75 (1978), where by a sharply divided vote (4 to 3) that court held that an educational degree was not property capable of division in marriage dissolution proceedings. Nonetheless, the majority in Graham did conclude that a spouse's contributions to the acquisition of a professional degree could be considered in matters of alimony for support and maintenance and for property settlement where marital property existed to be divided. It should further be noted that the Graham majority, unlike Washington, appears to consider goodwill as not a community asset subject to distribution.

    In In re Marriage of Horstmann, 263 N.W.2d 885 (Iowa 1978), the Iowa Supreme Court agreed with the pronouncement of the Colorado Supreme Court in Graham that a professional degree is not an asset to be considered in the distribution of the marital property. However, the court held that the increased earning potential made possible by the degree was an asset for distribution by the court. The court said, at page 891:

    We hold a trial court in a dissolution case where proper evidence is presented may consider the future earning capacities of both parties and in determining those capacities it may consider the education, skill or talent of both parties. This statement of principle, articulated in Schantz [v. Schantz, 163 N.W.2d 398 (Iowa *1891968)], applies to the court's determination of an equitable distribution of assets and property and to a determination of whether alimony should be awarded and, if so, to the amount to be awarded. In re Marriage of Beeh, 214 N.W.2d 170, 174 (Iowa 1974).

    In Wisner v. Wisner, 129 Ariz. 333, 631 P.2d 115, 122-23 (Ct. App. 1981), the court held that while an education itself is not properly subject to division in a dissolution of marriage proceeding, it is still a factor to be considered, in addition to others, in arriving at an equitable property division and in determining manner of spousal maintenance and child support:

    We agree with the majority opinion in Graham that education is an intangible property right, the value of which, because of its character, cannot properly be characterized as property subject to division between the spouses. In our opinion, the marital property concept simply "does not fit." However, while an education itself is not property subject to division, it is still a factor to be considered, in addition to others, in arriving at an equitable property division and in determining matters of spousal maintenance and child support. Thus, while education, along with the potential for greater earning capacity which can accompany it, is doubtless a factor to be considered by the trial judge in determining what distribution of property would be "equitable", and is even more obviously relevant upon the issue of spousal maintenance, it cannot be deemed property as such within the meaning of the Arizona statute.

    (Citations omitted.) Wisner, at 340-41.

    In In re Marriage of Vanet, 544 S.W.2d 236 (Mo. Ct. App. 1976), the court held that a professional education and right to practice in a particular field are in the nature of a financial resource and a realistic assessment properly entails consideration of anticipated earning capacity.

    Recently the Court of Appeals of Michigan in Woodworth v. Woodworth, 126 Mich. App. 258, 260-61, 337 N.W.2d 332, 334 (1983) held that the husband's law degree, which was the end product of a concerted family effort, was marital property subject to distribution upon dissolution of *190the marriage:

    The facts reveal that plaintiffs law degree was the end product of a concerted family effort. Both parties planned their family life around the effort to attain plaintiff's degree. Toward this end, the family divided the daily tasks encountered in living. While the law degree did not pre-empt all other facets of their lives, it did become the main focus and goal of their activities. Plaintiff left his job in Jonesville and the family relocated to Detroit so that plaintiff could attend law school. In Detroit, defendant sought and obtained full-time employment to support the family.
    We conclude, therefore, that plaintiff's law degree was the result of mutual sacrifice and effort by both plaintiff and defendant. While plaintiff studied and attended classes, defendant carried her share of the burden as well as sharing vicariously in the stress of the experience known as the "paper chase".
    We believe that fairness dictates that the spouse who did not earn an advanced degree be compensated whenever the advanced degree is the product of such concerted family investment. The degree holder has expended great effort to obtain the degree not only for himself or herself, but also to benefit the family as a whole. The other spouse has shared in this effort and contributed in other ways as well, not merely as a gift to the student spouse nor merely to share individually in the benefits but to help the marital unit as a whole.

    Numerous other states have also granted relief to the supporting spouse based in part on increased earning capacity. See, e.g., Moss v. Moss, 639 S.W.2d 370 (Ky. Ct. App. 1982); DeLa Rosa v. DeLa Rosa, 309 N.W.2d 755 (Minn. 1981); Hubbard v. Hubbard, 603 P.2d 747 (Okla. 1979); O'Brien v. O'Brien, 114 Misc. 2d 233, 452 N.Y.S.2d 801 (1982); Daniels v. Daniels, 20 Ohio Ops. 2d 458, 185 N.E.2d 773 (Ct. App. 1961). See also Ind. Code § 31-1-11.5-ll(c) (1980), overruling Wilcox v. Wilcox, 173 Ind. App. 661, 365 N.E.2d 792 (1977).

    Accordingly, I would characterize the professional education as a marital asset in the context of increased earning capacity subject to distribution.

    *191II

    Having determined that the professional degree is an asset of the marital community, we must next determine what method of valuation should be used to compensate the supporting spouse.

    I reject the restitution and rehabilitation methods adopted by the majority. Application of these methods can be seen in the New Jersey decisions of Mahoney v. Mahoney, 91 N.J. 488, 453 A.2d 527 (1982); Hill v. Hill, 91 N.J. 506, 453 A.2d 537 (1982); Lynn v. Lynn, 91 N.J. 510, 453 A.2d 539 (1982).

    An assumption that a professional education is solely a monetary purchase underlies the restitution and rehabilitation method of valuation. The court merely measures the supporting spouse's recovery by the amount of contributions to attainment of the degree and loss of earnings to the community while the student spouse is attaining an education, together with opportunities the supporting spouse has forgone.

    This measure of recovery undercompensates the supporting spouse by completely ignoring the value of the professional education as a marital asset. Acquiring an education represents more than a mere monetary contribution and forfeiture of opportunity. Limiting the recovery to restitution and rehabilitation (lost opportunity) does not provide the supporting spouse his/her expectation of economic benefit from the career for which the education laid the foundation. The degree was a family investment, rather than a gift or benefit to the degree holder alone. See Woodworth v. Woodworth, 126 Mich. App. 258, 337 N.W.2d 332 (1983); Pinnel, Divorce After Professional School: Education and Future Earning Capacity May Be Marital Property, 44 Mo. L. Rev. 329, 335 (1979); Loper, Horstmann v. Horst-mann: Present Right To Practice a Profession as Marital Property, 56 Den. L.J. 677, 689 (1979). A just and equitable distribution of this asset requires valuation of the increased earning capacity inherent in a professional education.

    Placing a value on an individual's earning potential is not *192compensation for a failed expectation that the professional spouse would realize his/her full economic potential. Rather the valuation is upon the effect of the present right to practice a particular profession on the spouse's earning capacity. See Note, Family Law: Ought a Professional Degree Be Divisible As Property Upon Divorce?, 22 Wm. & Mary L. Rev. 517 (1981); Comment, The Interest of the Community in a Professional Education, 10 Cal. W. L. Rev. 590 (1974).

    The Michigan Court of Appeals set forth the relevant factors in valuing a professional degree:

    [T]he length of the marriage after the degree was obtained, the sources and extent of financial support given plaintiff during his years in law school, and the overall division of the parties' marital property. In determining the degree's present value, the trial court should estimate what the person holding the degree is likely to make in that particular job market and subtract from that what he or she would probably have earned without the degree. Recompense for Financing Spouse's Education: Legal Protection for the Marital Investor in Human Capital, 28 Kan L Rev 379, 382-384 (1980).

    (Footnote omitted.) Woodworth v. Woodworth, 126 Mich. App. at 269.

    The Supreme Court of Kentucky in Inman v. Inman, 648 S.W.2d 847 (Ky. 1982) indicated that if the issue were before the court, the proper formula to be followed in placing a value on an educational degree secured by a spouse, to which the other spouse contributed financially, is to measure the recovery by the amount of money the nonstudent spouse contributed toward living expenses, the amount of money contributed for educational costs, and the potential for increase in future earning capacity made possible by the degree, thus not treating the degree as marital property.

    The method for valuation of the increased earning capacity should require a comparison of the student spouse's earning capacity at the time of marriage with that at the time of dissolution or permanent separation. From this value a just and equitable distribution should be made *193between the parties. Where a marriage has endured for some time after the degree is obtained, the supporting spouse may already have been benefited from the increased earning capacity and such should be taken into account in making a just and equitable distribution. Because this method of calculation is akin to the method used to ascertain damages for loss of earnings in a tort or wrongful death action, a body of knowledge already exists in the field of economics to make this type determination.

    Ill

    Turning to the cases before the court, I would reverse and remand both decisions for a valuation of the professional education and a just and equitable distribution in accordance with the mandate of RCW 26.09.080. In the event that there is insufficient property to make a just and equitable award to the supporting spouse, the trial court may award a lump sum payment to be distributed by the professional spouse in periodic payments over a reasonable period of time.

    Case-law data current through December 31, 2025. Source: CourtListener bulk data.

    ↑ + \ No newline at end of file diff --git a/.research/washburn.txt b/.research/washburn.txt new file mode 100644 index 0000000..be33789 --- /dev/null +++ b/.research/washburn.txt @@ -0,0 +1 @@ +In Re the Marriage of Washburn, 677 P.2d 152 (Wash. 1984) | HallApproved.com Hall Approved Free Access to American Case Law Statutes Free Legal Archive / Washington / Cases / Washington Supreme Court / 1984 / Washington Supreme Court, 1984 Copy citation Free Legal Archive / Washington / Cases / Washington Supreme Court / 1984 / In Re the Marriage of Washburn In Re the Marriage of Washburn Washington Supreme Court · Decided February 16, 1984 · Dimmick, Rosellini, Williams, Stafford, Utter, Brachtenbach, Dolliver, Dore, Pearson 677 P.2d 152; 101 Wash. 2d 168; 1984 Wash. LEXIS 1508 (Pacific Reporter, Second Series) In Re the Marriage of Washburn Opinions Opinion of the Court Dissenting Opinion Opinion of the Court Dimmick, J. When one spouse supports the other through professional school in the mutual expectation that the community will enjoy the financial benefit flowing from the resulting professional degree, but the marriage is dissolved before that benefit can be realized, should the supporting spouse be compensated? Our answer is yes. The contribution of the supporting spouse to the attainment of a professional degree by the student spouse is a factor to be considered in dividing property and liabilities pursuant to RCW 26.09.080, or in awarding maintenance pursuant to RCW 26.09.090. The Washburn court failed to consider Mrs. Washburn's contribution to her husband's education in any respect. We thus reverse and remand for consideration of the appropriate compensation due Mrs. Washburn. The Gillette court did value Mrs. Gillette's contribution to Mr. Gillette's education and supplemented its property division with a lump-sum award of $19,000, to be paid over time. We affirm this award. I A. Washburn. The parties were married in 1971 while they were juniors at the University of Idaho. Upon their graduation in 1973, both parties worked. In the fall of 1974 they moved to Pullman, Washington, so that Mr. Wash-burn could attend veterinary school at Washington State University. From the fall of 1974 until February 1978 Mr. Washburn attended classes and held summer and part-time employment. During this same period Mrs. Washburn *171 worked full time. The parties then moved to Kentucky to allow Mr. Washburn to participate in an internship. Mr. Washburn received his degree in June 1978. Upon Mr. Washburn's graduation the parties moved to Michigan where Mr. Washburn served an internship. Mrs. Washburn worked full time until their child was born in April 1979. In July 1979 the parties returned to Snohomish, where Mr. Washburn began practice as a veterinarian. They separated in January 1981 and a decree of dissolution was entered in June. The trial court found that the parties' family home had been sold during the separation and the $4,400 proceeds equally divided. It awarded the remaining community property to the party in possession thereof (approximately $3,500 to Mrs. Washburn and $5,700 to Mr. Washburn) and required Mr. Washburn to pay all community debts, including educational loans. The trial court denied Mrs. Washburn's request for maintenance. The court also declined to characterize Mr. Washburn's degree as property, and refused to admit expert testimony which would have established the value of the degree through comparison of Mr. Washburn's earning potentials with and without it. Finally, it concluded that a judgment in favor of one spouse as against the other as compensation for contribution toward the cost of an education was impermissible. Mrs. Washburn appeals that portion of the court's conclusion of law relating to Mr. Washburn's degree. B. Gillette. The parties were married in 1968. In 1970 they both contributed equally to the purchase of a ranch. The ranch operation, however, failed. In 1974 the parties agreed that Mr. Gillette should obtain a degree in veterinary medicine. The trial court, in an unchallenged finding of fact, found that at this time the parties both anticipated they would share equally in the expected increased earning capacity of Mr. Gillette and agreed to undertake the effort. The court in addition found that Mr. Gillette promised Mrs. Gillette that if she would support him during his years in school, she would never have to work again. *172 Mr. Gillette obtained his undergraduate degree in biology in 1978 from Eastern Oregon State College and was accepted into the veterinary college at Washington State University. The parties separated in October 1981. During Mr. Gillette's schooling and while the parties were together, Mrs. Gillette worked full time, contributing her income and money from a personal injury settlement. She turned down offers of job promotions so that she could move with her husband to Washington State University. Mr. Gillette worked part time, and also received gifts from his father and disability payments. Mr. Gillette obtained his degree in veterinary medicine in 1982. A decree of dissolution was entered in March 1983. The trial court found that the parties' lifestyle had been modest and their net worth diminished during the time Mr. Gillette had attended school. It affirmed the parties' own division of their community property (approximately $13,295 to Mrs. Gillette and $7,540 to Mr. Gillette). It charged Mr. Gillette with the educational loans incurred prior to and after separation. Mrs. Gillette agreed to pay past taxes. The trial court concluded that neither the professional degree nor the increased earning capacity resulting from that degree were property subject to division. However, it awarded Mrs. Gillette a judgment of $19,000 as an "equitable right to restitution," which it calculated as follows: During the 7%-year period the Petitioner was in school, the Respondent contributed an excess of $24,000.00 to the community. It is reasonable to assume that she consumed one-half that amount. During that time she lived a more spartan life than would have otherwise been necessary. There is no source of funds at present from which to order immediate repayment. Inflation had a very dramatic effect upon the value of the dollar during the period of the Petitioner's schooling. Petitioner has therefore benefited from the $12,000.00 excess contribution. The wife is receiving property and liabilities with a net value of $8,800.00 more than one-half of the parties' net worth and that sum is therefore subtracted from *173 $12,000.00, leaving a $3,200.00 deficit. An additional sum of $12,000.00 should be added to reimburse the wife for TVi years of reduced living standards and a reduced opportunity to accumulate property. This is based upon the theory that if the Petitioner had worked full-time instead of going to school he would have at least equalled Respondent's earnings, and the Respondent would have benefited from one-half of that increased earning ability. In addition, the wife would have had better working conditions and security had she taken the promotions offered at the time. The $12,000.00 added to $3,200.00 equals $15,200.00. To adjust for inflation, the figure should be increased by 25%, which adds $3,800.00 for a total of $19,000.00. Conclusion of law 4. Clerk's Papers, at 75-76. The trial court also found Mrs. Gillette was entitled to maintenance in the amount of $1 per year. Mr. Gillette appeals from the portion of the decree requiring him to pay $19,000 and maintenance. Mrs. Gillette cross-appeals contending Mr. Gillette's increased earning capacity resulting from the education is property which should be valued and divided. II The cases at bar are representative of a situation which is so familiar as to be almost a cliche. A husband and wife make the mutual decision that one of them will support the other while he or she obtains a professional degree. The educational years will be lean ones for the family not only because of heavy educational expenses, but also because the student spouse will be able to earn little or nothing. Moreover, the supporting spouse may be called upon to postpone his or her own education or forgo promotions and other valuable career opportunities in order to find a job near the student spouse's school. These sacrifices are made in the mutual expectation that the family will enjoy a higher standard of living once the degree is obtained. But dissolution of the marriage intervenes. Because the family spent most of its financial resources on the degree, there may be few or no assets to be distributed. The student spouse has *174 the degree and the increased earning potential that it represents, while the supporting spouse has only a dissolution decree. A Other courts have responded to this all too common situation in a variety of ways. A few appellate courts adopt the view that the professional degree (or the enhanced earning potential which it represents) is property which must be valued and distributed upon dissolution of the marriage. These courts differ in their valuation of the degree or earning potential. See Woodworth v. Woodworth, 126 Mich. App. 258 , 337 N.W.2d 332 (1983); In re Marriage of Horstmann, 263 N.W.2d 885 (Iowa 1978). 1 Another line of cases holds that, although a professional degree is not property, the supporting spouse is entitled to restitution of the money he or she spent toward the attainment of the degree, in order to prevent unjust enrichment of the student spouse. The formula used to determine the amount of restitution varies from court to court. See Hubbard v. Hubbard, 603 P.2d 747 (Okla. 1979); DeLa Rosa v. DeLa Rosa, 309 N.W.2d 755 (Minn. 1981). Still other courts find the solution in an award of maintenance to the supporting spouse. One court grants "reimbursement alimony" equal to the amount spent by the supporting spouse toward the education. See Mahoney v. Mahoney, 91 N.J. 488 , 453 A.2d 527 (1982). Others recog *175 nize the contribution of the supporting spouse as a basis for awarding maintenance, but do not prescribe a formula for determining the amount. See Moss v. Moss, 80 Mich. App. 693 , 264 N.W.2d 97 , appeal denied, 402 Mich. 946 (1978); Magruder v. Magruder, 190 Neb. 573 , 209 N.W.2d 585 (1973); Daniels v. Daniels, 20 Ohio Ops. 2d 458, 185 N.E.2d 773 (Ct. App. 1961); In re Marriage of Lundberg, 107 Wis. 2d 1 , 318 N.W.2d 918 (1982). Another approach is to consider the supporting spouse's contribution to the attainment of the professional degree when dividing marital assets between the parties. See In re Marriage of McVey, 641 P.2d 300 (Colo. Ct. App. 1981); Vaclav v. Vaclav, 96 Mich. App. 584 , 293 N.W.2d 613 (1980); In re Marriage of Vanet, 544 S.W.2d 236 (Mo. Ct. App. 1976). Finally, some courts simply deny any recovery to the supporting spouse. See Wisner v. Wisner, 129 Ariz. 333 , 631 P.2d 115 (Ct. App. 1981); In re Marriage of Sullivan, 134 Cal. App. 3d 484 , 184 Cal. Rptr. 796 (1982); In re Marriage of Graham, 194 Colo. 429 , 574 P.2d 75 (1978); In re Marriage of Goldstein, 97 Ill. App. 3d 1023 , 423 N.E.2d 1201 (1981); Wilcox v. Wilcox, 173 Ind. App. 661 , 365 N.E.2d 792 (1977); Severs v. Severs, 426 So. 2d 992 (Fla. Dist. Ct. App. 1983); Muckleroy v. Muckleroy, 84 N.M. 14 , 498 P.2d 1357 (1972); Lesman v. Lesman, 88 A.D.2d 153 , 452 N.Y.S.2d 935 (1982); Frausto v. Frausto, 611 S.W.2d 656 (Tex. Civ. App. 1980). Generally, these courts deny recovery because they cannot find a legal label for the requested award which seems to fit. Designation of the degree as "property" which may be valued and equitably divided is rejected because the degree, which cannot be sold, assigned or inherited, lacks the traditional attributes of property. See Graham, at 432. Unjust enrichment, which would place a value on the supporting spouse's contribution, is rejected as inappropriate in the context of marriage, which is "more than an economic undertaking." Lesman , at 159. Maintenance is rejected because the supporting spouse is capable of self-support. Wilcox , at 665. The ability to *176 consider the supporting spouse's contribution in dividing marital assets is acknowledged, but proves useless because there are no assets. See Graham, at 433. B In view of the fact that fault is an impermissible consideration in a dissolution proceeding in this state, 2 we are disinclined to compensate the supporting spouse under the theory of unjust enrichment, as was done in Hubbard and DeLa Rosa . Unjust enrichment is a contract implied at law requiring a person to make restitution to the extent he has been unjustly enriched. Not only must the person be enriched, but the enrichment must be unjust. Truckweld Equip. Co. v. Olson, 26 Wn. App. 638, 646 , 618 P.2d 1017 (1980). To require trial courts to determine whether the student spouse had been unjustly enriched by the efforts of the supporting spouse would invite the introduction of evidence as to who was at fault in the termination of the marriage before the fruits of the degree could be realized. Nor are we inclined to address at this time the somewhat metaphysical question of whether a professional degree is "property." However, we need not join the ranks of those courts which deny recovery. The liberal provisions of our dissolution of marriage act, codified in RCW 26.09, provide a flexible way for courts to fairly compensate supporting spouses in the state of Washington. RCW 26.09.080 governs the distribution of property and liabilities: In a proceeding for dissolution of the marriage, legal separation, declaration of invalidity, or in a proceeding for disposition of property following dissolution of the marriage by a court which lacked personal jurisdiction over the absent spouse or lacked jurisdiction to dispose of *177 the property, the court shall, without regard to marital misconduct, make such disposition of the property and the liabilities of the parties, either community or separate, as shall appear just and equitable after considering all relevant factors including, but not limited to: (1) The nature and extent of the community property; (2) The nature and extent of the separate property; (3) The duration of the marriage; and (4) The economic circumstances of each spouse at the time the division of property is to become effective, including the desirability of awarding the family home or the right to live therein for reasonable periods to a spouse having custody of any children. As this provision makes clear, a division of property and liabilities is controlled not by their character as separate or community, but rather by what is just and equitable, taking into account the economic circumstances of the parties. All relevant factors must be considered by the trial court in its attempt to achieve an equitable distribution. RCW 26.09.090 controls the awarding of maintenance: (1) In a proceeding for dissolution of marriage, legal separation, declaration of invalidity, or in a proceeding for maintenance following dissolution of the marriage by a court which lacked personal jurisdiction over the absent spouse, the court may grant a maintenance order for either spouse. The maintenance order shall be in such amounts and for such periods of time as the court deems just, without regard to marital misconduct, after considering all relevant factors including but not limited to: (a) The financial resources of the party seeking maintenance, including separate or community property apportioned to him, and his ability to meet his needs independently, including the extent to which a provision for support of a child living with the party includes a sum for that party as custodian; (b) The time necessary to acquire sufficient education or training to enable the party seeking maintenance to find employment appropriate to his skill, interests, style of life, and other attendant circumstances; (c) The standard of living established during the marriage; (d) The duration of the marriage; (e) The age, physical and emotional condition, and *178 financial obligations of the spouse seeking maintenance; and (f) The ability of the spouse from whom maintenance is sought to meet his needs and financial obligations while meeting those of the spouse seeking maintenance. Under this provision, the only limitation placed upon the trial court's ability to award maintenance is that the amount and duration, considering all relevant factors, be just. Additionally, RCW 26.09.170 authorizes the court to continue the maintenance obligation beyond the death of either party or the remarriage of the party receiving maintenance. When a person supports a spouse through professional school in the mutual expectation of future financial benefit to the community, but the marriage ends before that benefit can be realized, that circumstance is a "relevant factor" which must be considered in making a fair and equitable division of property and liabilities pursuant to RCW 26.09.080, or a just award of maintenance pursuant to RCW 26.09.090. A professional degree confers high earning potential upon the holder. The student spouse should not walk away with this valuable advantage without compensating the person who helped him or her obtain it. We have said that the supporting spouse may be compensated through a division of property and liabilities. In many cases, however, the wealth of the marriage will have been spent toward the cost of the professional degree, leaving few or no assets to divide. Where the assets of the parties are insufficient to permit compensation to be effected entirely through property division, a supplemental award of maintenance is appropriate. With respect to maintenance, we recognize that the spouse who is capable of supporting someone through school will in most cases also be capable of supporting him or herself after the marriage is dissolved. However, under the extremely flexible provisions of RCW 26.09.090, a demonstrated capacity of self-support does not automatically preclude an award of maintenance. Indeed, the ability of *179 the spouse seeking maintenance to meet his or her needs independently is only one factor to be considered. RCW 26.09.090(l)(a). The duration of the marriage and the standard of living established during the marriage must also be considered, making it clear that maintenance is not just a means of providing bare necessities, but rather a flexible tool by which the parties' standard of living may be equalized for an appropriate period of time. RCW 26.09-.090(l)(c), (d). Moreover, the factors listed in the statute are not exclusive. The trial court may consider the supporting spouse's contribution and exercise its broad discretion to grant maintenance, thereby in effect allowing the supporting spouse to share, temporarily, in the lifestyle which he or she helped the student spouse to attain. 3 In making an equitable property division or awarding maintenance, the trial court exercises broad discretionary powers. Its disposition will not be overturned on appeal absent a showing of manifest abuse of discretion. See Baker v. Baker, 80 Wn.2d 736, 747 , 498 P.2d 315 (1972); In re Marriage of Glorfield, 27 Wn. App. 358, 360 , 617 P.2d 1051 , review denied, 94 Wn.2d 1025 (1980); In re Marriage of Nicholson, 17 Wn. App. 110, 116 , 561 P.2d 1116 (1977). We are reluctant to encroach upon this discretion by providing a precise formula prescribing the amount of property to be distributed or maintenance to be awarded to the supporting spouse. Instead, we direct the trial court to consider the following factors, among others, in determining the proper amount of compensation for the supporting spouse: 1. The amount of community funds expended for direct *180 educational costs, including tuition, fees, books, and supplies. We do not include living expenses incurred by the student spouse as a factor because those expenses would have existed regardless of whether the student spouse pursued a professional education. 2. The amount which the community would have earned had the efforts of the student spouse not been directed toward his or her studies. By including this factor, we do not imply that parties to a marriage have a general duty to the community to realize their full economic potential. However, when the parties to a marriage make the joint decision that one spouse should obtain a professional degree or license, the community sacrifices not only the funds spent for direct educational or training costs, but also the earnings of the student spouse, if he or she would otherwise have been working. These sacrifices were made in the expectation that the community would receive financial benefit in the form of increased future earnings. When this expectation is frustrated by dissolution of the marriage, it would be inconsistent to permit the trial court to compensate the supporting spouse for the funds spent, but not the funds forgone. 3. Any educational or career opportunities which the supporting spouse gave up in order to obtain sufficiently lucrative employment, or to move to the city where the student spouse wished to attend school. 4. The future earning prospects of each spouse, including the earning potential of the student spouse with the professional degree. Factors 1 and 2 reflect funds sacrificed by the community in order to obtain the education or training; accordingly, the supporting spouse should be awarded no more than his or her one-half interest therein. The trial court may take the effect of inflation during the educational years into account. Factor 3 is included to permit the trial court to adjust the property division or maintenance award as appears just and equitable, in light of the opportunities *181 forfeited by the supporting spouse. 4 Factor 4 simply applies to the present context the long-standing rule that the economic condition in which a dissolution decree leaves the parties is a paramount concern in determining issues of property division and maintenance. See DeRuwe v. DeRuwe, 72 Wn.2d 404, 408 , 433 P.2d 209 (1967); In re Marriage of Dessauer, 97 Wn.2d 831, 839 , 650 P.2d 1099 (1982). We point out that where a marriage endures for some time after the professional degree is obtained, the supporting spouse may already have benefited financially from the student spouse's increased earning capacity to an extent that would make extra compensation inappropriate. For example, he or she may have enjoyed a high standard of living for several years. Or perhaps the professional degree made possible the accumulation of substantial community assets which may be equitably divided. However, our attention today is centered on the more difficult case of the marriage that is dissolved before the supporting spouse has realized a return on his or her investment in family prosperity. Some might object that by recognizing the supporting spouse's right to compensation, we are treating marriage as a commercial enterprise. That is not our intent nor the result of this decision. Rather, as was well stated by the court in Mahoney v. Mahoney, 91 N.J. 488, 500 , 453 A.2d 527 (1982): This Court does not support reimbursement between former spouses in alimony proceedings as a general principle. Marriage is not a business arrangement in which the parties keep track of debits and credits, their accounts to be settled upon divorce. Rather, as we have said, "marriage is a shared enterprise, a joint undertaking ... in many ways it is akin to a partnership." But every *182 joint undertaking has its bounds of fairness. Where a partner to marriage takes the benefits of his spouse's support in obtaining a professional degree or license with the understanding that future benefits will accrue and inure to both of them, and the marriage is then terminated without the supported spouse giving anything in return, an unfairness has occurred that calls for a remedy. (Citations omitted.) Turning to the cases before us today, we note that Mrs. Gillette supported her husband through undergraduate and veterinary school in the mutual expectation that they would both share in the increased earnings which the veterinary degree would produce. Indeed, Mr. Gillette promised his wife that once he received his degree, she would never have to work again. These expectations were shattered when the parties separated only months before Mr. Gillette received his veterinary degree. The parties agreed upon a division of community assets, leaving the trial court little opportunity to compensate Mrs. Gillette entirely through property division. To supplement the property division, the court awarded Mrs. Gillette $19,000 as an "equitable right to restitution," based upon her contribution to the attainment of the veterinary degree. The court made this lump-sum award payable over time, thereby reducing the burden on Mr. Gillette. The trial court labeled its $19,000 award "restitution." However, because the award will be paid in installments, thereby equalizing the parties' standard of living for a limited time, it is in effect an award of lump-sum maintenance. Our concern is not the particular label applied to this award, but rather its fairness as determined by those factors set out in RCW 26.09.090. See In re Marriage of Hadley, 88 Wn.2d 649, 658 , 565 P.2d 790 (1977). The trial court calculated the amount of its award to Mrs. Gillette without the benefit of the four factors set forth as guidelines herein. However, RCW 26.09.090 places emphasis on the justness of an award, not its method of calculation. Here, Mrs. Gillette supported her husband *183 through IV2 years of school. She turned down offers of job promotions to follow him to Washington State University. Under these circumstances, we cannot say that the trial court's award of $19,000 was a manifest abuse of discretion. See In re Marriage of Nicholson, 17 Wn. App. 110 , 561 P.2d 1116 (1977). Because the $19,000 award is in effect maintenance, the trial court's order requiring Mr. Gillette to pay maintenance in the amount of $1 per year is unnecessary and is reversed. We affirm, however, the portion of that same order which provides that the award shall not terminate upon Mrs. Gillette's remarriage or death, so that her right to receive the full $19,000 may be preserved. We turn next to the Washburn case. Mrs. Washburn worked full time to support Mr. Washburn while he attended veterinary school. Less than 2 years after Mr. Washburn began practice as a veterinarian, the marriage was dissolved. Nevertheless, the trial judge concluded he was unable to compensate Mrs. Washburn for her contribution to her husband's education, stating: I don't believe that I am prepared, nor am I convinced I'd be authorized to make, enter a judgment in favor of one spouse as against the other as compensation, and that's really what we are speaking of, compensation for the broken, lost, destroyed hopes and aspirations that the parties had, either when they got married or during the early years of their marriage. In this case there is just nothing, no asset to divide. When and if our Supreme Court comes to the point of holding that I can make a division or can in effect make a division of future earning potential, separate and apart from any physical or tangible asset of the parties, maybe we will have a new approach to the dissolution, I do not feel prepared to innovate that type of approach. Clerk's Papers, at 29-30 (oral ruling of the court). Under our opinion today, Mrs. Washburn may be entitled to an award as compensation for her contribution to her husband's education. Such compensation may be effected through property division, maintenance, or a com *184 bination of both. Although Mrs. Washburn did not appeal from the trial court's denial of maintenance, she did appeal the broader issue of whether she was entitled to a judgment as compensation for her contribution toward the cost of her husband's education. We reverse the Washburn court's conclusion of law that a judgment as compensation for contribution toward the cost of an education is impermissible, and remand for consideration of the compensation due Mrs. Washburn. Gillette is affirmed. Washburn is reversed in relevant part and remanded. Williams, C.J., and Stafford, Utter, Brachtenbach, Dolliver, Dore, and Pearson, JJ., concur. Inman v. Inman, 578 S.W.2d 266 (Ky. Ct. App. 1979), modified, 8 Fam. L. Rep. (BNA) 2329 (Ky. Ct. App. Mar. 12, 1982), rev'd, 648 S.W.2d 847 (Ky. 1982) is often cited as support for the proposition that a professional degree is marital property in which the supporting spouse has an interest. The authority of the original Inman decision is questionable in light of the later decision in the same case by the Kentucky Supreme Court. The Kentucky Supreme Court stated in dicta that an educational degree received by one spouse while the other spouse contributes financially to the cost of obtaining the degree is not, upon dissolution of the marriage, marital property. The court did, however, recognize the need to fairly compensate the supporting spouse when the marriage ends before the family realizes the expected benefits of the degree. Inman v. Inman, 648 S.W.2d 847, 852 (Ky. 1982). The dissolution of marriage act of 1973 eliminated fault as a relevant consideration in a dissolution proceeding. Under RCW 26.09.030, the sole basis for dissolution of a marriage is that it is irretrievably broken. RCW 26.09.080 and RCW 26.09.090 further provide that marital misconduct is not to be considered by the court in distributing the property and liabilities of the parties, or awarding maintenance. We wish to emphasize that by permitting the supporting spouse to be compensated with an award of maintenance, we are not subjecting the student spouse to some form of involuntary servitude by requiring him or her to work at the chosen profession against his or her will. The ability of the student spouse to pay maintenance is a relevant factor which must be considered in making an award to the supporting spouse. RCW 26.09.090(1) (f). If the student spouse permanently abandons his or her profession, and his or her ability to pay is substantially impaired as a result, this change of circumstances might justify a modification of the maintenance awarded to the supporting spouse. RCW 26.09.170. Another solution available to trial courts in similar cases which was not sought by either Mrs. Washburn or Mrs. Gillette is to allow the supporting spouse to obtain an equal educational opportunity at the student spouse's expense. See Childers v. Childers, 15 Wn. App. 792 , 552 P.2d 83 (1976), aff'd in relevant part, 89 Wn.2d 592 , 575 P.2d 201 (1978). Dissenting Opinion Rosellini, J. (dissenting) — This case involves the twin issues of characterization and valuation of a spouse's professional education. The majority declines to address whether the professional degree should be characterized as property, and simply holds that the expectation of future financial benefit derived from supporting a spouse through professional school is a relevant "factor" which must be considered in making a just and equitable division of property and liabilities or a just maintenance award. While I am in general agreement with this holding, I would characterize this interest as a marital asset in the context of increased earning capacity subject to distribution. The majority's holding on the issue of valuation/recovery is limited to an award to the supporting spouse in the form of reimbursement and/or rehabilitative maintenance or property distribution. I do not agree that such an award is a just and equitable distribution of the assets of the community. I would hold that the value of the educational degree is measured by the increased earning capacity inherent in the particular education and as such is subject to a just and equitable distribution. I The dissolution of marriage act, RCW 26.09, provides a *185 flexible manner of determining what are the assets of the community subject to distribution and includes the respective earning capacities of the parties. RCW 26.09.080 reads in part: In a proceeding for dissolution of the marriage, legal separation, . . . the court shall, without regard to marital misconduct, make such disposition of the property and the liabilities of the parties, either community or separate, as shall appear just and equitable after considering all relevant factors including, but not limited to: (1) The nature and extent of the community property; (2) The nature and extent of the separate property; (3) The duration of the marriage; and (4) The economic circumstances of each spouse at the time the division of property is to become effective, including the desirability of awarding the family home or the right to live therein for reasonable periods to a spouse having custody of any children. In addition to the four subsections in RCW 26.09.080, which include " [t]he economic circumstances of each spouse at the time the division of property is to become effective," the court should also consider the age, health, education and employment history of the parties and their children, and the future earning prospects of all of them in determining a just and equitable division. DeRuwe v. DeRuwe, 72 Wn.2d 404, 408 , 433 P.2d 209 (1967); In re Marriage of Rink, 18 Wn. App. 549, 551 , 571 P.2d 210 (1977). See also Comment, Property Dispositions in Dissolution Proceedings: The Criteria in Washington, 12 Gonz. L. Rev. 492 (1977); Reike, The Dissolution Act of 1973: From Status to Contract?, 49 Wash. L. Rev. 375 , 403-05 (1974). Additionally, RCW 26.09.090 sets forth the factors to be considered by a trial court in determining the propriety of a maintenance award. These factors include the financial resources, health and education of the respective parties, the duration of the marriage and the standard of living established therein. Support for characterizing the professional education degree as a divisible asset is found in other areas of intan *186 gible and speculative property rights considered to be divisible upon dissolution. The accounting concept of goodwill, like an advanced professional degree, is by nature an asset with an elusive value. However, this court and the lower appellate courts have held that professional goodwill, although intangible and commonly defined as the expectation of continued public patronage, is a factor which has a value and should be included among the assets distributed upon a marriage dissolution. In re Marriage of Fleege, 91 Wn.2d 324 , 588 P.2d 1136 (1979); In re Marriage of Kaplan, 23 Wn. App. 503 , 597 P.2d 439 (1979); In re Marriage of Freedman, 35 Wn. App. 49 , 665 P.2d 902 , review denied, 100 Wn.2d 1019 (1983); In re Marriage of Lukens, 16 Wn. App. 481 , 558 P.2d 279 (1976), review denied, 88 Wn.2d 1011 (1977). While the goodwill of a particular professional practice may not be marketable and the determination of its value difficult, it is nonetheless an asset of the community because it has a value to the professional spouse. Fleege, at 326-27; Freedman, at 52. The nonprofessional spouse, having contributed to the building of the professional practice through the provision of services, financial, domestic, or otherwise, has a valuable interest in the goodwill of the professional spouse's practice. The mere fact that goodwill is an amorphous asset and a value cannot be precisely determined is an improper basis for a court's refusal to acknowledge and to consider the existence of the goodwill value when dividing the value of a professional practice between spouses in a marital dissolution proceeding. Fleege, at 327-30; Lukens, at 484. Methods of placing a value on professional goodwill vary according to the circumstances of each case. Factors considered when valuing the goodwill of a professional practice include the length of time that the professional spouse has practiced, the comparative success of the spouse's professional practice, the professional spouse's age and health, the past profits of the practice, the fixed resources of the practice, and the physical assets of the practice. Fleege, at 326; *187 Lukens, at 484. The crucial point for our inquiry is not the means by which goodwill is valued, but that a property interest is found in an intangible. The divisibility of pension and retirement benefits of an employed spouse upon dissolution provides another analogy to support the proposition that the professional degree be considered an asset subject to distribution. Even though pension and retirement benefits normally are not mature, but are future interests, contingent future interests, or even expectancies, the benefits may have a value to both spouses that is capable of division as property. See Wilder v. Wilder, 85 Wn.2d 364 , 534 P.2d 1355 (1975); DeRevere v. DeRevere, 5 Wn. App. 741 , 491 P.2d 249 (1971). See also Foster & Freed, Spousal Rights in Retirement and Pension Benefits, 16 J. Fam. L. 187 (1977-78). In a wrongful death or a personal injury action, courts consistently have recognized the need to determine the value of a professional education in order to compensate fully a plaintiff for loss of future income. Damages in a personal injury or wrongful death action are unliquidated; no one fixed mathematical formula is used to decide each case. Rather, each case involves different facts, considerations, and probabilities to which courts cannot attempt to apply a formula. Instead, courts must assume that each situation is unique and recognize that a determination of damages involves some speculation, uncertainty, and arbitrariness. Courts, however, rarely deny a remedy for lost future earning capacity in a personal injury or wrongful death action merely because assessing future earning capacity involves the court in some speculation. We should be equally hesitant to deny relief to a nonstudent spouse who has lost the economic potential of the partial value of the education that she helped to provide. See Peck & Hopkins, Economics and Impaired Earning Capacity in Personal Injury Cases, 44 Wash. L. Rev. 351 (1969). A court easily can extend the tort concept of valuation of future earning capacity to a situation in which the support *188 ing spouse will lose the economic benefits of the degreed spouse's education upon dissolution of the marriage. The nonstudent spouse will lose the same expectancy as the plaintiff will in the personal injury or wrongful death action. See Comment, The Interest of the Community in a Professional Education, 10 Cal. W. L. Rev. 590 (1974). A number of recent cases from sister jurisdictions have held that the supporting spouse is entitled to a distribution of increased earning potential for his or her support of the family while the other spouse obtained an education. The leading case cited most often for the proposition that a professional degree is not property is the Colorado Supreme Court decision of Graham v. Graham, 194 Colo. 429 , 574 P.2d 75 (1978), where by a sharply divided vote (4 to 3) that court held that an educational degree was not property capable of division in marriage dissolution proceedings. Nonetheless, the majority in Graham did conclude that a spouse's contributions to the acquisition of a professional degree could be considered in matters of alimony for support and maintenance and for property settlement where marital property existed to be divided. It should further be noted that the Graham majority, unlike Washington, appears to consider goodwill as not a community asset subject to distribution. In In re Marriage of Horstmann, 263 N.W.2d 885 (Iowa 1978), the Iowa Supreme Court agreed with the pronouncement of the Colorado Supreme Court in Graham that a professional degree is not an asset to be considered in the distribution of the marital property. However, the court held that the increased earning potential made possible by the degree was an asset for distribution by the court. The court said, at page 891: We hold a trial court in a dissolution case where proper evidence is presented may consider the future earning capacities of both parties and in determining those capacities it may consider the education, skill or talent of both parties. This statement of principle, articulated in Schantz [v. Schantz, 163 N.W.2d 398 (Iowa *189 1968)], applies to the court's determination of an equitable distribution of assets and property and to a determination of whether alimony should be awarded and, if so, to the amount to be awarded. In re Marriage of Beeh, 214 N.W.2d 170, 174 (Iowa 1974). In Wisner v. Wisner, 129 Ariz. 333 , 631 P.2d 115, 122-23 (Ct. App. 1981), the court held that while an education itself is not properly subject to division in a dissolution of marriage proceeding, it is still a factor to be considered, in addition to others, in arriving at an equitable property division and in determining manner of spousal maintenance and child support: We agree with the majority opinion in Graham that education is an intangible property right, the value of which, because of its character, cannot properly be characterized as property subject to division between the spouses. In our opinion, the marital property concept simply "does not fit." However, while an education itself is not property subject to division, it is still a factor to be considered, in addition to others, in arriving at an equitable property division and in determining matters of spousal maintenance and child support. Thus, while education, along with the potential for greater earning capacity which can accompany it, is doubtless a factor to be considered by the trial judge in determining what distribution of property would be "equitable", and is even more obviously relevant upon the issue of spousal maintenance, it cannot be deemed property as such within the meaning of the Arizona statute. (Citations omitted.) Wisner , at 340-41. In In re Marriage of Vanet, 544 S.W.2d 236 (Mo. Ct. App. 1976), the court held that a professional education and right to practice in a particular field are in the nature of a financial resource and a realistic assessment properly entails consideration of anticipated earning capacity. Recently the Court of Appeals of Michigan in Woodworth v. Woodworth, 126 Mich. App. 258, 260-61 , 337 N.W.2d 332, 334 (1983) held that the husband's law degree, which was the end product of a concerted family effort, was marital property subject to distribution upon dissolution of *190 the marriage: The facts reveal that plaintiffs law degree was the end product of a concerted family effort. Both parties planned their family life around the effort to attain plaintiff's degree. Toward this end, the family divided the daily tasks encountered in living. While the law degree did not pre-empt all other facets of their lives, it did become the main focus and goal of their activities. Plaintiff left his job in Jonesville and the family relocated to Detroit so that plaintiff could attend law school. In Detroit, defendant sought and obtained full-time employment to support the family. We conclude, therefore, that plaintiff's law degree was the result of mutual sacrifice and effort by both plaintiff and defendant. While plaintiff studied and attended classes, defendant carried her share of the burden as well as sharing vicariously in the stress of the experience known as the "paper chase". We believe that fairness dictates that the spouse who did not earn an advanced degree be compensated whenever the advanced degree is the product of such concerted family investment. The degree holder has expended great effort to obtain the degree not only for himself or herself, but also to benefit the family as a whole. The other spouse has shared in this effort and contributed in other ways as well, not merely as a gift to the student spouse nor merely to share individually in the benefits but to help the marital unit as a whole. Numerous other states have also granted relief to the supporting spouse based in part on increased earning capacity. See, e.g., Moss v. Moss, 639 S.W.2d 370 (Ky. Ct. App. 1982); DeLa Rosa v. DeLa Rosa, 309 N.W.2d 755 (Minn. 1981); Hubbard v. Hubbard, 603 P.2d 747 (Okla. 1979); O'Brien v. O'Brien, 114 Misc. 2d 233 , 452 N.Y.S.2d 801 (1982); Daniels v. Daniels, 20 Ohio Ops. 2d 458, 185 N.E.2d 773 (Ct. App. 1961). See also Ind. Code § 31-1-11.5 -ll(c) (1980), overruling Wilcox v. Wilcox, 173 Ind. App. 661 , 365 N.E.2d 792 (1977). Accordingly, I would characterize the professional education as a marital asset in the context of increased earning capacity subject to distribution. *191 II Having determined that the professional degree is an asset of the marital community, we must next determine what method of valuation should be used to compensate the supporting spouse. I reject the restitution and rehabilitation methods adopted by the majority. Application of these methods can be seen in the New Jersey decisions of Mahoney v. Mahoney, 91 N.J. 488 , 453 A.2d 527 (1982); Hill v. Hill, 91 N.J. 506 , 453 A.2d 537 (1982); Lynn v. Lynn, 91 N.J. 510 , 453 A.2d 539 (1982). An assumption that a professional education is solely a monetary purchase underlies the restitution and rehabilitation method of valuation. The court merely measures the supporting spouse's recovery by the amount of contributions to attainment of the degree and loss of earnings to the community while the student spouse is attaining an education, together with opportunities the supporting spouse has forgone. This measure of recovery undercompensates the supporting spouse by completely ignoring the value of the professional education as a marital asset. Acquiring an education represents more than a mere monetary contribution and forfeiture of opportunity. Limiting the recovery to restitution and rehabilitation (lost opportunity) does not provide the supporting spouse his/her expectation of economic benefit from the career for which the education laid the foundation. The degree was a family investment, rather than a gift or benefit to the degree holder alone. See Woodworth v. Woodworth, 126 Mich. App. 258 , 337 N.W.2d 332 (1983); Pinnel, Divorce After Professional School: Education and Future Earning Capacity May Be Marital Property, 44 Mo. L. Rev. 329 , 335 (1979); Loper, Horstmann v. Horst-mann: Present Right To Practice a Profession as Marital Property, 56 Den. L.J. 677, 689 (1979). A just and equitable distribution of this asset requires valuation of the increased earning capacity inherent in a professional education. Placing a value on an individual's earning potential is not *192 compensation for a failed expectation that the professional spouse would realize his/her full economic potential. Rather the valuation is upon the effect of the present right to practice a particular profession on the spouse's earning capacity. See Note, Family Law: Ought a Professional Degree Be Divisible As Property Upon Divorce?, 22 Wm. & Mary L. Rev. 517 (1981); Comment, The Interest of the Community in a Professional Education, 10 Cal. W. L. Rev. 590 (1974). The Michigan Court of Appeals set forth the relevant factors in valuing a professional degree: [T]he length of the marriage after the degree was obtained, the sources and extent of financial support given plaintiff during his years in law school, and the overall division of the parties' marital property. In determining the degree's present value, the trial court should estimate what the person holding the degree is likely to make in that particular job market and subtract from that what he or she would probably have earned without the degree. Recompense for Financing Spouse's Education: Legal Protection for the Marital Investor in Human Capital, 28 Kan L Rev 379, 382-384 (1980). (Footnote omitted.) Woodworth v. Woodworth, 126 Mich. App. at 269 . The Supreme Court of Kentucky in Inman v. Inman, 648 S.W.2d 847 (Ky. 1982) indicated that if the issue were before the court, the proper formula to be followed in placing a value on an educational degree secured by a spouse, to which the other spouse contributed financially, is to measure the recovery by the amount of money the nonstudent spouse contributed toward living expenses, the amount of money contributed for educational costs, and the potential for increase in future earning capacity made possible by the degree, thus not treating the degree as marital property. The method for valuation of the increased earning capacity should require a comparison of the student spouse's earning capacity at the time of marriage with that at the time of dissolution or permanent separation. From this value a just and equitable distribution should be made *193 between the parties. Where a marriage has endured for some time after the degree is obtained, the supporting spouse may already have been benefited from the increased earning capacity and such should be taken into account in making a just and equitable distribution. Because this method of calculation is akin to the method used to ascertain damages for loss of earnings in a tort or wrongful death action, a body of knowledge already exists in the field of economics to make this type determination. Ill Turning to the cases before the court, I would reverse and remand both decisions for a valuation of the professional education and a just and equitable distribution in accordance with the mandate of RCW 26.09.080. In the event that there is insufficient property to make a just and equitable award to the supporting spouse, the trial court may award a lump sum payment to be distributed by the professional spouse in periodic payments over a reasonable period of time. 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    +You have sent too many requests in a given amount of time. + diff --git a/.research/white_vlex.txt b/.research/white_vlex.txt new file mode 100644 index 0000000..a3bb8d7 --- /dev/null +++ b/.research/white_vlex.txt @@ -0,0 +1 @@ +White v. White (White v. White, 20 P.3d 481, 105 Wn. App. 545, 105 Wash. App. 545 (Wash. App. 2001)) - vLex United States VINCENT AI Legal Research Coverage DOCKET ALARM Login Sign Up Home Case Law White v. White Document Cited authorities (19) Cited in (23) Precedent Map Related Court Washington Court of Appeals Writing for the Court MORGAN, J. Citation White v. White, 20 P.3d 481, 105 Wn. App. 545, 105 Wash. App. 545 (Wash. App. 2001) Decision Date 30 March 2001 Docket Number No. 23917-5-II. Parties In re the Marriage of Carol Ann WHITE, Respondent, v. William Frank WHITE, Petitioner. 20 P.3d 481 105 Wn. App. 545 105 Wash. App. 545 In re the Marriage of Carol Ann WHITE , Respondent , v. William Frank WHITE , Petitioner . No. 23917-5 -II. Court of Appeals of Washington, Division 2 . March 30, 2001 . Christopher R. Sundstrom , Vancouver, for Respondent . Douglas O Whitlock , Whitlock & Saunders, Vancouver, for Appellant . MORGAN , J. The husband in this dissolution action appeals the trial court 's division of property. We think the trial court had discretion to divide the property as it did, but we cannot sustain its reasoning. Accordingly, we grant the husband an opportunity for reconsideration. Carol Ann White (Carol) and William Frank White ( Frank ) were married in 1973 , separated in 1997 , and divorced in 1998 . During marriage and before 1993 , they acquired a family home subject to a mortgage and a family car subject to a security interest. 1 It is undisputed that the home and car were community property when initially acquired. In early 1993 , Carol received an inheritance from her father . Later in 1993 , she used $4,000 of it to pay off the family car. In May 1994 , she used $26,511 of it to pay off the family home. The sum of those payments, $30,511, is the amount presently in dispute. In June 1997 , Carol petitioned for dissolution. A year later, the case went to a bench trial. Carol asked that she be awarded $30,511 as her separate property, and that the remaining property be divided equally. She reasoned that the $30,511 was her separate property when she acquired it by inheritance; that it remained her separate property even after she applied it to the family home and car, unless she intended to give it to the community; that Frank had the burden of proving she intended to give it to the community; that Frank had not met his burden; and thus that the $30,511 was still her separate property at the time of trial. She concluded that her separate property should be awarded to her. Frank asked that the parties ' property be divided equally. He reasoned that the $30,511 was Carol's separate property when she acquired it by inheritance; that it became community property when Carol applied it to the house and car, unless Carol intended not to give it to the community; that Carol had the burden of proving the lack of such intent; that Carol had not met her burden; and that the $30,511 was community property at the time of trial. He concluded that community property should be divided equally. The trial court embraced Carol's reasoning. It found or concluded in its oral ruling, written findings, or both, that the $30,511 was Carol's separate property when she first inherited it; that the $30,511 was not transformed into community property at the time Carol used it to pay off the house and car unless Carol intended to give it to the community; that Frank had the burden of proving such intent; that Frank had failed to meet his burden; and that the $30,511 was still Carol's separate property at the time of trial. 2 In its decree, however, the trial court awarded Carol the first $26,511 of value in the family home, and each party " [o] ne half the net equity of the family home ... minus the [$] 26,511.30 the wife was awarded as her separate property." 3 It also awarded Carol the first $4,000 of value in the family car, "which shall be considered the wife's separate property [,] " 4 and each party one half the remainder. It distributed the other assets and debts in approximately equal fashion. The question on appeal is whether the trial court properly characterized and awarded the $30,511 as separate property. Carol answers yes, while Frank answers no. A trial court has broad discretion when distributing property in a dissolution case. 5 Under appropriate circumstances, it need not divide community property equally, 6 and it need not award separate property to its owner. 7 According to RCW 26.09.080 , the court need only "make such disposition of the property and the liabilities of the parties , either community or separate, as shall appear just and equitable after considering all relevant factors [.] " When exercising this broad discretion, a trial court focuses on the assets then before it-i.e., on the parties ' assets at the time of trial. 8 If one or both parties disposed of an asset before trial, the court simply has no ability to distribute that asset at trial. When exercising its broad discretion, a trial court characterizes each asset as separate or community property. 9 The asset is separate property if acquired before marriage; 10 acquired during marriage by gift or inheritance; 11 acquired during marriage with the traceable proceeds of separate property; 12 or, in the case of earnings or accumulations, acquired during permanent separation. 13 The asset is community property if it is not separate property, 14 which generally means that an asset is community property if acquired onerously during marriage. 15 An asset is characterized as of the date of its acquisition, 16 and its character does not change thereafter, 17 subject to exceptions not pertinent here, 18 regardless of whether the asset is improved, or its value enhanced, by property of a different character. 19 When exercising its discretion, a trial court is permitted to consider, as one relevant factor, a spouse's unusually significant contributions to (or wasting of) the assets on hand at trial. As Division Three has noted, " Washington courts recognize that consideration of each party 's responsibility for creating or dissipating marital assets is relevant to the just and equitable distribution of property." 20 Applying these principles here, we hold that the trial court had discretion to do what it did, for the following reasons: (1) The assets before the court at trial, and thus the assets to be distributed at trial, were the family home and family car. (2) The home and car were community property when first acquired, because they were acquired onerously during marriage. (3) The home and car remained community property, even after Carol used part of her separate-property inheritance to pay them off, because the character of an asset does not change after acquisition. (4) The home and car were community property at trial, regardless of whether Carol intended, in 1993 and 1994 , to donate the $30,511 to the community. (5) Even though the home and car were community property at trial, the court had discretion to award them, or their value, in any way that was just and equitable; it was not required to divide them equally. (6) Given that Carol made an unusually significant contribution to the value of the home and car when she used $30,511 of her inheritance to pay the debts against them, it was just and equitable to distribute the home and car (a) by awarding Carol the first $4,000 of value in the car and the first $26,511 of value in the home; and (b) by awarding each party half the remaining value. Although the trial court had discretion to do what it did for the foregoing reasons, it did not use those reasons. Instead, as already seen above, it reasoned as follows: (1) The asset to be distributed at trial was the $30,511 that Carol received from her father . (2) The $30,511 was Carol's separate property when she first acquired it, because she acquired it by inheritance. (3) The $30,511 remained her separate property after she spent it to pay off the house and car-unless, when she spent it, she intended to give it to the community. (4) Frank had the burden of proving that she intended to give it to the community, and he did not meet that burden at trial. (5) Accordingly, the $30,511 was Carol's separate property at trial, and it should be awarded to her as such. The first of these propositions is incorrect. The family home and family car, not the $30,511, were the assets before the court for distribution at trial. The $30,511 did not exist as an asset after it was spent. The second of these propositions is correct-and also immaterial to the characterization of the home or car. It may be considered as a factor bearing on the distribution of the home and car, given that the $30,511 was contributed to the home and car. The third proposition is incorrect. When the $30,511 was spent to pay off the debts on the home and car, it ceased to exist as a separate asset, and it lost whatever character it previously had. In effect, it merged into the home and car without altering their community character, whether or not Carol intended a gift and whether or not she later traced her contribution to her separate inheritance. 21 The fourth proposition is immaterial to the characterization of the home and car. Whether Carol intended to make a gift to the community is a relevant factor to consider when dividing the community estate, but it is not a fact that either party had to prove or disprove before the trial court could exercise its discretion. The fifth proposition is as incorrect as the others. The $30,511 had no character after it was spent, and it could not be awarded as a separate-property asset on hand at trial. In reaching these conclusions, we do not overlook Frank's reliance on In re Marriage of Hurd. 22 Hurd holds "that a spouse's use of his or her separate funds to purchase property in the names of both spouses, absent any other explanation, permits a presumption that the purchase or transaction was intended as a gift to the community." 23 Hurd would apply, assuming it is correct, if Carol had used the $30,511 to purchase the family home or family car. In that situation, her intent to give (or lack of intent to give) would determine the character of the $30,511; the character of the $30,511 would determine the character of the home and car at least in part; and thus her intent to give (or lack of intent to give) would be highly material. Hurd does not apply, however, even assuming it is correct, where Carol used the $30,511 to pay off the home and car that had previously been acquired. Regardless of her intent to give, if any, the use of $30,511 in ... 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Underwood United States Washington Court of Appeals June 3, 2014 ... ... “Under appropriate circumstances ... [the trial court] need not award separate property to its owner.” In re Marriage of White , 105 Wash.App. 545, 549, 20 P.3d 481 (2001). Larson, 178 Wash.App. at 138, 313 P.3d 1228. ¶ 82 Because the trial court is in the ... ... In re Marriage of Van De Graaf United States Washington Court of Appeals August 29, 2019 ... ... at 268. The court is not required to place the parties in precisely equal financial positions at the moment of dissolution. In re Marriage of White , 105 Wn. App. 545, 549, 20 P.3d 481 (2001). If, as here, the spouses were in a long-term marriage of 25 years or more, the court's objective is to ... ... Triggs v. Triggs United States Washington Court of Appeals August 25, 2011 ... ... In re Marriage of Konzen, 103 Wn.2d 470, 477-78, 693 P.2d 97, cert. denied, 473 U.S. 906 (1985); see also In re Marriage of White , 105 Wn. App. 545, 549, 20 P.3d 481 (2001) (recognizing that the trial court is not required to divide community property equally) ... ... Patton v. Patton United States Washington Court of Appeals September 16, 2003 ... ... --------------- ... 1. Clerk's Papers (CP) at 5-6 ... 2. Friedlander v. Friedlander, 80 Wn.2d 293, 305, 494 P.2d 208 (1972); White v. White , 105 Wn. App. 545, 549, 20 P.3d 481 (2001) ... 3. White , 105 Wn. App. at 549 ... 4. White , 105 Wn. App. at 551; In re Marriage of ... ... Get Started for Free 4 books & journal articles Table of Cases United States Washington State Bar Association Washington Family Law Deskbook (WSBA) Table of Cases Invalid date ...White v. White, 51 Wn.2d 652, 321 P.2d 262 (1958) . . . . . . . . . . . . . . . . . . . . . 28.07[2] White, In re Marriage of, 105 Wn. App. 545 , 20 P.3d 481 (2001) . . . . . . . . . . . . . . . . 30.06[3]; 32.04[5] White, State ex rel. v. Douglas, 6 Wn.2d 356, 107 P.2d 593 (1940) 70.04 Whit...... § 3.04 RIGHT OF REIMBURSEMENT: THE EQUITABLE LIEN United States Washington State Bar Association Washington Community Property Deskbook (WSBA) (2023 Ed.) Chapter 3 Character of Ownership of Property Invalid date ...In re Pugh's Estate, 18 Wn.2d 501, 139 P.2d 698 (1943); Strand v. Pekola, 18 Wn.2d 164, 138 P.2d 204 (1943); In re Marriage of White, 105 Wn. App. 545 , 553, 20 P.3d 481 (2001). In the court's view, such improvements upon property do not change the legal title to it, but do subject it to cer...... §30.06 Equitable Liens United States Washington State Bar Association Washington Family Law Deskbook (WSBA) Chapter 30 Identification of Property Interests Invalid date ...to contest the resolution of her claim to the property was during the prior litigation over that property. See White v. White, 105 Wn. App. 545 , 549, 20 P.3d 481 (2001) ("If one or both parties disposed of an asset before trial, the court simply has no ability to distribute that asset at... §32.04 Factors Born From Case Law United States Washington State Bar Association Washington Family Law Deskbook (WSBA) Chapter 32 Disposition of Property and Liabilities Invalid date ...for creating or dissipating marital assets is relevant to the just and equitable distribution of property. In re Marriage of White, 105 Wn. App. 545 , 551, 20 P.3d 481 (2001). In evaluating a party's assets, ' "the trial court may properly consider a spouse's waste or concealment of assets,'...... 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    Washington Supreme Court, 1999 +

    In Re Marriage of Zahm

    In Re Marriage of Zahm
    Washington Supreme Court · Decided June 17, 1999 · Johnson
    978 P.2d 498 +(Pacific Reporter, Second Series)

    In Re Marriage of Zahm

    Opinion

    978 P.2d 498 (1999)
    138 Wash.2d 213

    In re the MARRIAGE OF L. Dianne ZAHM, Respondent, and
    Kermit A. Zahm, Petitioner.

    No. 66895-7.

    Supreme Court of Washington, En Banc.

    Argued February 24, 1999.
    Decided June 17, 1999.

    *499 William S. Lowry, Walla Walla, Christopher Constantine, Tacoma, for Petitioner.

    Albert Golden, Walla Walla, for Respondent.

    JOHNSON, J.

    This case primarily involves the judicial characterization of social security payments when dividing property in a marital dissolution action. We must decide whether the trial court properly characterized petitioner's social security benefits, an Idaho bank account, and a home in Walla Walla, Washington. Petitioner also claims the trial court erred in awarding maintenance to respondent. We affirm the Court of Appeals.

    FACTS

    Petitioner and respondent married in June 1978. They separated in 1986 and divorced in 1987. Approximately 18 months later, the Zahms reunited and the 1987 divorce decree was set aside and the action dismissed. The couple permanently separated in 1995. As *500 part of the Zahms' marital dissolution proceeding, the trial court characterized and distributed the couple's separate and community property.

    Both petitioner and respondent brought separate property to their 1978 marriage. Prior to her marriage to petitioner, respondent owned a townhouse in Eagle, Idaho. The Zahms resided at the Eagle, Idaho townhouse for approximately the first two years of their marriage. Respondent then sold her townhouse and placed the sale proceeds into bank accounts in her name and the names of her daughters from a previous marriage. In addition to those accounts, respondent also maintained separate accounts for herself and her daughters with New York Life Insurance. At the conclusion of the Zahms' marital dissolution proceeding, the trial court characterized the bank accounts originally established with proceeds of the Idaho townhouse sale, and the New York Life Insurance account as respondent's separate property.

    Petitioner owned a townhouse in Boise, Idaho prior to marrying respondent. In 1983, while married to respondent, petitioner paid the balance in full on his townhouse. He then sold that house in 1988. The buyer's monthly payments on the Boise townhouse were placed in the Zahms' joint First Interstate Bank account in Washington (First Interstate/Washington). The First Interstate/Washington account was also funded by monies from a First Interstate Bank account in Idaho (First Interstate/Idaho). At the conclusion of the Zahms' marital dissolution proceeding, the trial court characterized the monies in both bank accounts as community property.

    In 1990, the Zahms purchased a home in Walla Walla and resided there. The Zahms split the down payment on the house, each paying approximately $9,000, and both signed a promissory note to secure a loan for the home's balance of $54,900. At the time of trial, the Walla Walla home had appreciated to a market value of $107,725. At the conclusion of the Zahms' marital dissolution proceeding, the trial court characterized the Walla Walla home as community property.

    In 1991 and 1993, petitioner assigned the interest in the buyer's note for the Boise home to Metropolitan Mortgage. Petitioner received over $55,000 from Metropolitan Mortgage, which was deposited into the First Interstate/Idaho account. The names on the First Interstate/Idaho account's signature card are those of petitioner, respondent and petitioner's son from a previous marriage. Petitioner claimed at trial that respondent's name appeared on the First Interstate/Idaho account exclusively for estate planning purposes and that respondent never signed checks on that account. In 1994, petitioner withdrew $51,223.57 from the First Interstate/Idaho account to pay the balance remaining on the Walla Walla home's mortgage. At the time of trial, the balance remaining in the First Interstate/Idaho account was $6,002.00; the trial court characterized those funds as community property.

    At the time of trial, petitioner received monthly income from federal social security, his military retirement plan, his Veterans Administration disability plan, his federal technician's pay, and his Idaho State retirement plan. These income sources totaled $3,762 per month. All these monies were automatically deposited every month into the First Interstate/Idaho Bank account. At the conclusion of the Zahms' marital dissolution proceeding, the trial court characterized these monies as community property. However, the trial court neither assigned nor calculated a future value of these monies as part of the court's property characterization and distribution.

    Respondent filed for divorce from petitioner in February 1995. A dissolution trial was conducted in November 1996. The superior court entered its findings of fact, conclusions of law, and a decree of dissolution on May 20, 1996. The court decree, inter alia, characterized the First Interstate/Idaho account, the Walla Walla home, and petitioner's social security benefits as community property. Petitioner was also ordered to pay maintenance for respondent. Petitioner appealed the trial court's decision. In its opinion, the Court of Appeals agreed with petitioner that the trial court improperly characterized his social security benefits, but found the error to be harmless. The court affirmed the trial *501 court on the remaining issues raised by petitioner. In re Marriage of Zahm, 91 Wash. App. 78, 955 P.2d 412 (1998). Petitioner timely appealed.

    ANALYSIS

    Petitioner argues the trial court erred when it included petitioner's social security benefits in its distribution of the Zahms' community property. Petitioner argues federal social security law generally makes monies payable under the social security system indivisible and not subject to reassignment. Petitioner contends these restrictions mandate our finding that the trial court's distribution of petitioner's benefits contravened federal law. The Court of Appeals agreed and ruled the trial court erred in listing petitioner's social security benefits as community property; however, the court found the error harmless. We affirm.

    RCW 26.09.080 governs the disposition of property in marital dissolution cases. That statute instructs trial courts to make a "just and equitable" distribution of the parties' property. The statute's nonexclusive list of factors for consideration by the trial court include the nature and extent of the community property, the nature and extent of the separate property, duration of the marriage, and the resulting economic circumstances of each spouse when the property is divided. RCW 26.09.080. A fair and equitable division by a trial court "does not require mathematical precision, but rather fairness, based upon a consideration of all the circumstances of the marriage, both past and present, and an evaluation of the future needs of parties." In re Marriage of Crosetto, 82 Wash.App. 545, 556, 918 P.2d 954 (1996).

    At issue here is the interplay between RCW 26.09.080 and 42 U.S.C. § 407(a) of the Social Security Act (Act), the latter of which forbids transfer or reassignment of "[t]he right of any person to any future payment under this subchapter...." While the Act does permit reassignment of social security benefits to pay for alimony or child support, it categorically excludes any similar payment obligation in conformity with a community property settlement, equitable distribution of property, or other division between spouses or former spouses. 42 U.S.C.A. § 659(i)(3)(B)(ii).

    In 1979, the United States Supreme Court held the federal constitution's supremacy clause preempted California's community property laws. Hisquierdo v. Hisquierdo, 439 U.S. 572, 590, 99 S.Ct. 802, 59 L.Ed.2d 1 (1979). The judicial application of California's community property laws, therefore, could not supplant the terms of the federal Railroad Retirement Act of 1974, 88 Stat. 1305, § 45 U.S.C. 231 (Railroad Retirement Act). Hisquierdo, 439 U.S. at 590, 99 S.Ct. 802. In its analysis, inter alia, the Supreme Court analogized between Railroad Retirement Act benefits and federal social security benefits holding, inasmuch as both benefits are the products of noncontractual agreements, they are fundamentally similar. Hisquierdo, 439 U.S. at 574-75, 99 S.Ct. 802. The Supreme Court ultimately held Railroad Retirement Act benefits are not subject to distribution as property in a dissolution proceeding. Hisquierdo, 439 U.S. at 590, 99 S.Ct. 802. Given the Supreme Court's assertion of an affinity between Railroad Retirement Act benefits and federal social security benefits in Hisquierdo, we conclude social security benefits themselves are not subject to division in a marital property distribution case. However, this conclusion does not resolve precisely the exact question presented here because while the trial court did characterize the social security benefits as community property, it did not order an actual distribution of those benefits.

    Following Hisquierdo, some state appellate courts have held social security benefits are not subject to distribution as community property. In Luna v. Luna, 125 Ariz. 120, 123, 608 P.2d 57 (1979), the Arizona Supreme Court held payments received by a spouse in the form of social security disability benefits were the receiving spouse's separate property and should not be characterized as community property. Likewise, in In re Marriage of Hillerman, 109 Cal.App.3d 334, 339-41, 167 Cal.Rptr. 240 (1980), the California Court of Appeals held, although social security plans and private pension plans are similar, peculiarities in the federal social security *502 plan render it insurmountably problematic to characterize and redistribute those benefits as community property, in the manner a court might properly do with private pension plan benefits. The California court also reasoned that problems in identifying social security benefits as community property were evidence of an implicit congressional intent to create a federal retirement benefit that would be immune from division by state courts in marital dissolution proceedings. In re Marriage of Hillerman, 109 Cal.App.3d at 341, 167 Cal.Rptr. 240.

    Although extrajurisdictional case law on this issue is scant, we conclude that federal statutes secure social security benefits as the separate indivisible property of the spouse who earned them. This approach ensures that the benefits intended for the beneficiary reach that party and that the benefits are insulated from the occasionally unpredictable fortunes of legal dispute. Hisquierdo, 439 U.S. at 584, 99 S.Ct. 802. Therefore, the trial court erred in characterizing petitioner's social security benefits as community property. However, although the trial court initially characterized the social security benefits as community property, the court did not apportion those benefits. Rather, the trial court merely noted under the community property portion of its findings of fact and conclusions of law that "61% of [petitioner's] social security was earned during marriage." Clerk's Papers at 140.

    Petitioner argues the trial court's initial characterization of his social security benefits as community property was factored into the distribution of the parties' assets, whether the benefits were ultimately apportioned or not. Petitioner would have us hold mere consideration by a trial court of a party's social security benefits in a marital dissolution proceeding is reversible error. We decline to so hold.

    In Hisquierdo, the respondent had requested the court provide her with "an offsetting award of presently available community property to compensate her for her interest in petitioner's expected [Railroad Retirement Act]'s benefits." Hisquierdo, 439 U.S. at 588, 99 S.Ct. 802. The Supreme Court found the proposed arrangement tantamount to the prohibited reassignment of federal benefits: "[a]n offsetting award...would upset the statutory balance and impair petitioner's economic security just as surely as would a regular deduction from his [or her] benefit check." Hisquierdo, 439 U.S. at 588, 99 S.Ct. 802.

    Hisquierdo is distinguishable from our case. Here, the trial court did not conduct the kind of valuation of benefits prohibited under Hisquierdo. The trial court neither computed a formal calculation of the value of petitioner's social security benefits nor offset a formal numerical valuation into the court's property division via a specific counterbalancing property award to respondent. Thus, the reasoning in Hisquierdo does not control the result in the case before us.

    While Hisquierdo is distinguishable, cases with more similar fact patterns have arisen in other jurisdictions. In 1997, the Supreme Judicial Court of Massachusetts held, although social security old age benefits may not be characterized as part of the marital estate for the purpose of property characterization, a judge may consider a spouse's social security benefits as a factor coequal with others when determining an equitable division of any distributable marital assets. Mahoney v. Mahoney, 425 Mass. 441, 446, 681 N.E.2d 852 (1997). In Mahoney, the trial court had considered the husband's anticipated social security old age benefits when distributing the marital assets, ultimately awarding the wife a larger percentage of the marital estate "`to equalize the standard of living both parties will enjoy in the present and future.'" Mahoney, 425 Mass. at 446, 681 N.E.2d 852. This approach was affirmed on appellate review.

    Cases similar to Mahoney have emerged from other state courts. Some courts have held, while the anti-reassignment clause of the Social Security Act precludes a trial court from directly dividing social security income in a divorce action, a trial court may still properly consider a spouse's social security income within the more elastic parameters of the court's power to formulate a just and equitable division of the parties' marital property. In re Marriage of Brane, 21 Kan. App.2d 778, 783, 908 P.2d 625 (1995); Pongonis *503 v. Pongonis, 606 A.2d 1055, 1058 (Me. 1992); Rudden v. Rudden, 765 S.W.2d 719, 720 (Mo.Ct.App. 1989). This approach is consistent with the objectives of RCW 26.09.080.

    While other cases are at odds with the approach taken by the Massachusetts, Kansas and Missouri state courts, these other holdings echo the reasoning in Hisquierdo and are, therefore, distinguishable from the subject case. For example, the Supreme Court of Oregon has held a trial court, in its division of marital property, may not properly consider the formal valuation of a spouse's social security benefits. In re Marriage of Swan, 301 Or. 167, 171, 720 P.2d 747 (1986); see also Wolff v. Wolff, 112 Nev. 1355, 1363, 929 P.2d 916 (1996); Olson v. Olson, 445 N.W.2d 1 (N.D. 1989). As noted above, the trial court here did not impermissibly calculate a specific formal valuation of petitioner's social security benefits and award respondent a precise property offset based on that valuation but, rather, merely considered those benefits when determining the parties' relative economic circumstances at dissolution.

    In its review of this case, the Court of Appeals adopted the approach of the Massachusetts, Kansas, and Missouri state courts and held it proper that trial courts consider social security benefits in determining the parties' relative economic circumstances at dissolution. The Court of Appeals reasoned that since, under RCW 26.09.080, a trial court making a just and equitable distribution is allowed to consider such relevant and nonexhaustive factors as "(1) The nature and extent of the community property; (2) The nature and extent of the separate property; (3) The duration of the marriage; and (4) The economic circumstances of each spouse at the time the division of property is to become effective ...,"[1] it is, therefore, permissible for a trial court to consider petitioner's social security benefits. "A trial court could not properly evaluate the economic circumstances of the spouses unless it could also consider the amount of social security benefits currently received." In re Zahm, 91 Wash.App. at 85, 955 P.2d 412. This resolution by the Court of Appeals is more consistent with the statutory goals of just and equitable distribution and we adopt it.

    Petitioner raises several additional issues. He argues the trial court erred when it characterized the Walla Walla home as community property and awarded the home to respondent.

    Property acquired during a marriage is presumed to be community in character. In re Marriage of Short, 125 Wash.2d 865, 870, 890 P.2d 12 (1995). In disputed cases, the question of whether property is community or separate is retrospectively determined by its character at the date the property was acquired. Baker v. Baker, 80 Wash.2d 736, 745, 498 P.2d 315 (1972). Where direct and positive evidence is proffered to the contrary, however, this presumption can be rebutted. In re Marriage of Olivares, 69 Wash.App. 324, 336, 848 P.2d 1281 (1993).

    Petitioner attempts to rebut this presumption by arguing that, under the facts associated with the Zahms' acquisition of the Walla Walla home, the so-called "mortgage rule" applies. In re Estate of Finn, 106 Wash. 137, 143-45, 179 P. 103 (1919). The mortgage rule is a legal tool used to characterize property acquired, using both community and separate funds, over a period of time. Harry M. Cross, The Community Property Law in Washington, 61 Wash. L.Rev. 13, 39-49 (rev. 1985). The mortgage rule examines whether both parties concerned were obligated to make payments in order to retain ownership of the disputed asset. If there was no such continuing obligation, then the character of the asset is retrospectively determined to be proportionate to the ratio of separate and/or community funds used to acquire the asset. Id.

    In this case, petitioner and respondent split equally the down payment for the Walla Walla home. Both signed the promissory note to Sterling Savings Bank to acquire the loan to pay the balance of the home's purchase price. However, petitioner argues since respondent had a nominal income at the time the Sterling Savings Bank loan was *504 secured, the loan was secured on the basis of petitioner's more substantial income. Petitioner relies on the trial testimony of a Sterling Savings Bank loan officer that loan officers weigh heavily an applicant's income when making decisions about loan requests. However, this particular officer was not working at the Sterling Savings Bank when the Zahms requested their Walla Walla home loan. Accordingly, the loan officer could not have known precisely what criteria were considered by the Zahms' approving officer and how the individual loan criterion was weighted. This testimony alone is insufficient to rebut the presumption that this property, acquired during the Zahms' marriage, is community in character.

    Furthermore, respondent's investment in the purchase of the Walla Walla home was equal with that of the petitioner. Respondent used her separate property (actually, in a slightly greater amount than that offered by petitioner) to pay the Walla Walla home's down payment. Both respondent and petitioner negotiated the financing of the Sterling Savings Bank loan. On the loan application, respondent listed her separate assets as totaling approximately $100,000, nearly double the amount of the bank loan. While respondent's income at the time may have been somewhat inadequate, her asset base was not. The Sterling Savings Bank loan officer that testified at trial did affirm that a loan applicant's assets are part of the criteria considered by bank officers when making decisions on loan requests.

    Finally, respondent signed the promissory note, making herself equally liable with petitioner for the repayment of the loan to third persons. When both the Zahms signed the promissory note, they created a community debt and the monies borrowed upon that debt were likewise community in character.

    Given the above formidable facts surrounding the acquisition of the Walla Walla home, petitioner has failed to rebut the presumption that the home was community property. As such, the trial court did not err in characterizing the home as community property. Both the trial court's award of the home to respondent and its award of a $30,000 lien on the home to petitioner were proper.

    We affirm the Court of Appeals on this issue.

    Petitioner argues the trial court erred when it characterized the funds in the First Interstate/Idaho Bank account as community property. Petitioner claims monies in that bank account were his separate property.

    The First Interstate Bank account at dispute is located outside of Washington State. The state law applied to determine the characterization of property is that of the state where the couple resided at the time the property was acquired. In re Marriage of Landry, 103 Wash.2d 807, 810, 699 P.2d 214 (1985). The Zahms were domiciled in Idaho at the time the disputed First Interstate/Idaho account was established; therefore, Idaho law governs.

    Property acquired during a marriage is presumed to be community in character under Idaho law. Weilmunster v. Weilmunster, 124 Idaho 227, 232, 858 P.2d 766 (Ct. App. 1993) (Idaho legal doctrine) (citing Stahl v. Stahl, 91 Idaho 794, 797-98, 430 P.2d 685 (1967)); In re Marriage of Short, 125 Wash.2d at 870, 890 P.2d 12 (Washington legal doctrine). The trial court here followed Idaho law in making its determinations regarding the First Interstate/Idaho Bank account.

    The presumption under Idaho law that the account was community property can be rebutted if the petitioner can prove with reasonable certainty and particularity the account contained commingled, separate property. Houska v. Houska, 95 Idaho 568, 570, 512 P.2d 1317 (1973). The incident of commingling separate property with community property will not transform the separate property's character into community property. Weilmunster, 124 Idaho at 227, 858 P.2d 766 (citing Stahl, 91 Idaho at 797-98, 430 P.2d 685). However, if the commingling of separate and community funds cannot be cogently unraveled through the presentation of evidence, Idaho's judicial presumption that the disputed property is community in nature is not rebutted. Martsch v. Martsch, 103 Idaho 142, 146, 645 P.2d 882 (1982).

    *505 Petitioner failed to marshal evidence sufficient to overcome the judicial presumption that the monies in the First Interstate/Idaho account are community property. Both petitioner's and respondent's names were on this account. Deposits made to this account resulted in the commingling of community and separate funds. Although petitioner attempted to parse out the alleged separate monies from the community monies in the First Interstate/Idaho Bank account, he was unsuccessful in doing so. There were substantial gaps in his recollection of the bank account's transactions. The trial court's finding that the First Interstate/Idaho Bank account was community property was proper.

    We affirm the Court of Appeals on this issue.

    Finally, petitioner argues the trial court erred by awarding respondent maintenance. The standard of review for the appeal of a maintenance award is abuse of discretion. In re Marriage of Mathews, 70 Wash.App. 116, 123, 853 P.2d 462 (1993). Both Washington statutory law and case law recognize the power of a trial court to award maintenance to either party after the court properly considers all the statutory factors relevant to such a decision. RCW 26.09.080; In re Marriage of Williams, 84 Wash.App. 263, 267-68, 927 P.2d 679 (1996). The trial court here considered these factors in its ruling and we find no abuse of discretion for its maintenance award to respondent.

    The trial court gave sufficient and tenable reasons for its application of RCW 26.09.090's fair and equitable factors in its division of the Zahms' property. Drawing from the evidence in the record, the trial court judge, on the record, arrayed the Zahms' incomes, resources, ages, medical conditions, and the ability of petitioner to provide maintenance. These factors were sufficiently adequate and justifiable. Petitioner's social security benefits were an appropriate element for the court to factor into its consideration of respondent's maintenance award for the same reasons contained in the analysis of petitioner's first claim regarding social security benefits.

    We affirm the Court of Appeals.

    GUY, C.J., DURHAM, SMITH, MADSEN, ALEXANDER, TALMADGE, SANDERS, and IRELAND, JJ., concur.

    NOTES

    [1] In re Marriage of Zahm, 91 Wash.App. at 84-85, 955 P.2d 412 (quoting RCW 26.09.080) (emphasis added).

    Case-law data current through December 31, 2025. Source: CourtListener bulk data.

    ↑ + \ No newline at end of file diff --git a/.research/zahm.txt b/.research/zahm.txt new file mode 100644 index 0000000..bf34fe6 --- /dev/null +++ b/.research/zahm.txt @@ -0,0 +1 @@ +In Re Marriage of Zahm, 978 P.2d 498 (Wash. 1999) | HallApproved.com Hall Approved Free Access to American Case Law Statutes Free Legal Archive / Washington / Cases / Washington Supreme Court / 1999 / Washington Supreme Court, 1999 Copy citation Free Legal Archive / Washington / Cases / Washington Supreme Court / 1999 / In Re Marriage of Zahm In Re Marriage of Zahm Washington Supreme Court · Decided June 17, 1999 · Johnson 978 P.2d 498 (Pacific Reporter, Second Series) In Re Marriage of Zahm Opinion 978 P.2d 498 (1999) 138 Wash.2d 213 In re the MARRIAGE OF L. Dianne ZAHM, Respondent, and Kermit A. Zahm, Petitioner. No. 66895-7. Supreme Court of Washington, En Banc. Argued February 24, 1999. Decided June 17, 1999. *499 William S. Lowry, Walla Walla, Christopher Constantine, Tacoma, for Petitioner. Albert Golden, Walla Walla, for Respondent. JOHNSON, J. This case primarily involves the judicial characterization of social security payments when dividing property in a marital dissolution action. We must decide whether the trial court properly characterized petitioner's social security benefits, an Idaho bank account, and a home in Walla Walla, Washington. Petitioner also claims the trial court erred in awarding maintenance to respondent. We affirm the Court of Appeals. FACTS Petitioner and respondent married in June 1978. They separated in 1986 and divorced in 1987. Approximately 18 months later, the Zahms reunited and the 1987 divorce decree was set aside and the action dismissed. The couple permanently separated in 1995. As *500 part of the Zahms' marital dissolution proceeding, the trial court characterized and distributed the couple's separate and community property. Both petitioner and respondent brought separate property to their 1978 marriage. Prior to her marriage to petitioner, respondent owned a townhouse in Eagle, Idaho. The Zahms resided at the Eagle, Idaho townhouse for approximately the first two years of their marriage. Respondent then sold her townhouse and placed the sale proceeds into bank accounts in her name and the names of her daughters from a previous marriage. In addition to those accounts, respondent also maintained separate accounts for herself and her daughters with New York Life Insurance. At the conclusion of the Zahms' marital dissolution proceeding, the trial court characterized the bank accounts originally established with proceeds of the Idaho townhouse sale, and the New York Life Insurance account as respondent's separate property. Petitioner owned a townhouse in Boise, Idaho prior to marrying respondent. In 1983, while married to respondent, petitioner paid the balance in full on his townhouse. He then sold that house in 1988. The buyer's monthly payments on the Boise townhouse were placed in the Zahms' joint First Interstate Bank account in Washington (First Interstate/Washington). The First Interstate/Washington account was also funded by monies from a First Interstate Bank account in Idaho (First Interstate/Idaho). At the conclusion of the Zahms' marital dissolution proceeding, the trial court characterized the monies in both bank accounts as community property. In 1990, the Zahms purchased a home in Walla Walla and resided there. The Zahms split the down payment on the house, each paying approximately $9,000, and both signed a promissory note to secure a loan for the home's balance of $54,900. At the time of trial, the Walla Walla home had appreciated to a market value of $107,725. At the conclusion of the Zahms' marital dissolution proceeding, the trial court characterized the Walla Walla home as community property. In 1991 and 1993, petitioner assigned the interest in the buyer's note for the Boise home to Metropolitan Mortgage. Petitioner received over $55,000 from Metropolitan Mortgage, which was deposited into the First Interstate/Idaho account. The names on the First Interstate/Idaho account's signature card are those of petitioner, respondent and petitioner's son from a previous marriage. Petitioner claimed at trial that respondent's name appeared on the First Interstate/Idaho account exclusively for estate planning purposes and that respondent never signed checks on that account. In 1994, petitioner withdrew $51,223.57 from the First Interstate/Idaho account to pay the balance remaining on the Walla Walla home's mortgage. At the time of trial, the balance remaining in the First Interstate/Idaho account was $6,002.00; the trial court characterized those funds as community property. At the time of trial, petitioner received monthly income from federal social security, his military retirement plan, his Veterans Administration disability plan, his federal technician's pay, and his Idaho State retirement plan. These income sources totaled $3,762 per month. All these monies were automatically deposited every month into the First Interstate/Idaho Bank account. At the conclusion of the Zahms' marital dissolution proceeding, the trial court characterized these monies as community property. However, the trial court neither assigned nor calculated a future value of these monies as part of the court's property characterization and distribution. Respondent filed for divorce from petitioner in February 1995. A dissolution trial was conducted in November 1996. The superior court entered its findings of fact, conclusions of law, and a decree of dissolution on May 20, 1996. The court decree, inter alia, characterized the First Interstate/Idaho account, the Walla Walla home, and petitioner's social security benefits as community property. Petitioner was also ordered to pay maintenance for respondent. Petitioner appealed the trial court's decision. In its opinion, the Court of Appeals agreed with petitioner that the trial court improperly characterized his social security benefits, but found the error to be harmless. The court affirmed the trial *501 court on the remaining issues raised by petitioner. In re Marriage of Zahm, 91 Wash. App. 78 , 955 P.2d 412 (1998). Petitioner timely appealed. ANALYSIS Petitioner argues the trial court erred when it included petitioner's social security benefits in its distribution of the Zahms' community property. Petitioner argues federal social security law generally makes monies payable under the social security system indivisible and not subject to reassignment. Petitioner contends these restrictions mandate our finding that the trial court's distribution of petitioner's benefits contravened federal law. The Court of Appeals agreed and ruled the trial court erred in listing petitioner's social security benefits as community property; however, the court found the error harmless. We affirm. RCW 26.09.080 governs the disposition of property in marital dissolution cases. That statute instructs trial courts to make a "just and equitable" distribution of the parties' property. The statute's nonexclusive list of factors for consideration by the trial court include the nature and extent of the community property, the nature and extent of the separate property, duration of the marriage, and the resulting economic circumstances of each spouse when the property is divided. RCW 26.09.080. A fair and equitable division by a trial court "does not require mathematical precision, but rather fairness, based upon a consideration of all the circumstances of the marriage, both past and present, and an evaluation of the future needs of parties." In re Marriage of Crosetto, 82 Wash.App. 545, 556 , 918 P.2d 954 (1996). At issue here is the interplay between RCW 26.09.080 and 42 U.S.C. § 407 (a) of the Social Security Act (Act), the latter of which forbids transfer or reassignment of "[t]he right of any person to any future payment under this subchapter...." While the Act does permit reassignment of social security benefits to pay for alimony or child support, it categorically excludes any similar payment obligation in conformity with a community property settlement, equitable distribution of property, or other division between spouses or former spouses. 42 U.S.C.A. § 659 (i)(3)(B)(ii). In 1979, the United States Supreme Court held the federal constitution's supremacy clause preempted California's community property laws. Hisquierdo v. Hisquierdo, 439 U.S. 572, 590 , 99 S.Ct. 802 , 59 L.Ed.2d 1 (1979). The judicial application of California's community property laws, therefore, could not supplant the terms of the federal Railroad Retirement Act of 1974, 88 Stat. 1305 , § 45 U.S.C. 231 (Railroad Retirement Act). Hisquierdo, 439 U.S. at 590 , 99 S.Ct. 802 . In its analysis, inter alia, the Supreme Court analogized between Railroad Retirement Act benefits and federal social security benefits holding, inasmuch as both benefits are the products of noncontractual agreements, they are fundamentally similar. Hisquierdo, 439 U.S. at 574-75 , 99 S.Ct. 802 . The Supreme Court ultimately held Railroad Retirement Act benefits are not subject to distribution as property in a dissolution proceeding. Hisquierdo, 439 U.S. at 590 , 99 S.Ct. 802 . Given the Supreme Court's assertion of an affinity between Railroad Retirement Act benefits and federal social security benefits in Hisquierdo , we conclude social security benefits themselves are not subject to division in a marital property distribution case. However, this conclusion does not resolve precisely the exact question presented here because while the trial court did characterize the social security benefits as community property, it did not order an actual distribution of those benefits. Following Hisquierdo , some state appellate courts have held social security benefits are not subject to distribution as community property. In Luna v. Luna, 125 Ariz. 120, 123 , 608 P.2d 57 (1979), the Arizona Supreme Court held payments received by a spouse in the form of social security disability benefits were the receiving spouse's separate property and should not be characterized as community property. Likewise, in In re Marriage of Hillerman, 109 Cal.App.3d 334, 339-41 , 167 Cal.Rptr. 240 (1980), the California Court of Appeals held, although social security plans and private pension plans are similar, peculiarities in the federal social security *502 plan render it insurmountably problematic to characterize and redistribute those benefits as community property, in the manner a court might properly do with private pension plan benefits. The California court also reasoned that problems in identifying social security benefits as community property were evidence of an implicit congressional intent to create a federal retirement benefit that would be immune from division by state courts in marital dissolution proceedings. In re Marriage of Hillerman, 109 Cal.App.3d at 341 , 167 Cal.Rptr. 240 . Although extrajurisdictional case law on this issue is scant, we conclude that federal statutes secure social security benefits as the separate indivisible property of the spouse who earned them. This approach ensures that the benefits intended for the beneficiary reach that party and that the benefits are insulated from the occasionally unpredictable fortunes of legal dispute. Hisquierdo, 439 U.S. at 584 , 99 S.Ct. 802 . Therefore, the trial court erred in characterizing petitioner's social security benefits as community property. However, although the trial court initially characterized the social security benefits as community property, the court did not apportion those benefits. Rather, the trial court merely noted under the community property portion of its findings of fact and conclusions of law that "61% of [petitioner's] social security was earned during marriage." Clerk's Papers at 140. Petitioner argues the trial court's initial characterization of his social security benefits as community property was factored into the distribution of the parties' assets, whether the benefits were ultimately apportioned or not. Petitioner would have us hold mere consideration by a trial court of a party's social security benefits in a marital dissolution proceeding is reversible error. We decline to so hold. In Hisquierdo , the respondent had requested the court provide her with "an offsetting award of presently available community property to compensate her for her interest in petitioner's expected [Railroad Retirement Act]'s benefits." Hisquierdo, 439 U.S. at 588 , 99 S.Ct. 802 . The Supreme Court found the proposed arrangement tantamount to the prohibited reassignment of federal benefits: "[a]n offsetting award...would upset the statutory balance and impair petitioner's economic security just as surely as would a regular deduction from his [or her] benefit check." Hisquierdo, 439 U.S. at 588 , 99 S.Ct. 802 . Hisquierdo is distinguishable from our case. Here, the trial court did not conduct the kind of valuation of benefits prohibited under Hisquierdo . The trial court neither computed a formal calculation of the value of petitioner's social security benefits nor offset a formal numerical valuation into the court's property division via a specific counterbalancing property award to respondent. Thus, the reasoning in Hisquierdo does not control the result in the case before us. While Hisquierdo is distinguishable, cases with more similar fact patterns have arisen in other jurisdictions. In 1997, the Supreme Judicial Court of Massachusetts held, although social security old age benefits may not be characterized as part of the marital estate for the purpose of property characterization, a judge may consider a spouse's social security benefits as a factor coequal with others when determining an equitable division of any distributable marital assets. Mahoney v. Mahoney, 425 Mass. 441, 446 , 681 N.E.2d 852 (1997). In Mahoney , the trial court had considered the husband's anticipated social security old age benefits when distributing the marital assets, ultimately awarding the wife a larger percentage of the marital estate "`to equalize the standard of living both parties will enjoy in the present and future.'" Mahoney, 425 Mass. at 446 , 681 N.E.2d 852 . This approach was affirmed on appellate review. Cases similar to Mahoney have emerged from other state courts. Some courts have held, while the anti-reassignment clause of the Social Security Act precludes a trial court from directly dividing social security income in a divorce action, a trial court may still properly consider a spouse's social security income within the more elastic parameters of the court's power to formulate a just and equitable division of the parties' marital property. In re Marriage of Brane, 21 Kan. App.2d 778, 783 , 908 P.2d 625 (1995); Pongonis *503 v. Pongonis, 606 A.2d 1055, 1058 (Me. 1992); Rudden v. Rudden, 765 S.W.2d 719, 720 (Mo.Ct.App. 1989). This approach is consistent with the objectives of RCW 26.09.080. While other cases are at odds with the approach taken by the Massachusetts, Kansas and Missouri state courts, these other holdings echo the reasoning in Hisquierdo and are, therefore, distinguishable from the subject case. For example, the Supreme Court of Oregon has held a trial court, in its division of marital property, may not properly consider the formal valuation of a spouse's social security benefits. In re Marriage of Swan, 301 Or. 167, 171 , 720 P.2d 747 (1986); see also Wolff v. Wolff, 112 Nev. 1355, 1363 , 929 P.2d 916 (1996); Olson v. Olson, 445 N.W.2d 1 (N.D. 1989). As noted above, the trial court here did not impermissibly calculate a specific formal valuation of petitioner's social security benefits and award respondent a precise property offset based on that valuation but, rather, merely considered those benefits when determining the parties' relative economic circumstances at dissolution. In its review of this case, the Court of Appeals adopted the approach of the Massachusetts, Kansas, and Missouri state courts and held it proper that trial courts consider social security benefits in determining the parties' relative economic circumstances at dissolution. The Court of Appeals reasoned that since, under RCW 26.09.080, a trial court making a just and equitable distribution is allowed to consider such relevant and nonexhaustive factors as "(1) The nature and extent of the community property; (2) The nature and extent of the separate property; (3) The duration of the marriage; and (4) The economic circumstances of each spouse at the time the division of property is to become effective ...," [1] it is, therefore, permissible for a trial court to consider petitioner's social security benefits. "A trial court could not properly evaluate the economic circumstances of the spouses unless it could also consider the amount of social security benefits currently received." In re Zahm, 91 Wash.App. at 85 , 955 P.2d 412 . This resolution by the Court of Appeals is more consistent with the statutory goals of just and equitable distribution and we adopt it. Petitioner raises several additional issues. He argues the trial court erred when it characterized the Walla Walla home as community property and awarded the home to respondent. Property acquired during a marriage is presumed to be community in character. In re Marriage of Short, 125 Wash.2d 865, 870 , 890 P.2d 12 (1995). In disputed cases, the question of whether property is community or separate is retrospectively determined by its character at the date the property was acquired. Baker v. Baker, 80 Wash.2d 736, 745 , 498 P.2d 315 (1972). Where direct and positive evidence is proffered to the contrary, however, this presumption can be rebutted. In re Marriage of Olivares, 69 Wash.App. 324, 336 , 848 P.2d 1281 (1993). Petitioner attempts to rebut this presumption by arguing that, under the facts associated with the Zahms' acquisition of the Walla Walla home, the so-called "mortgage rule" applies. In re Estate of Finn, 106 Wash. 137, 143-45 , 179 P. 103 (1919). The mortgage rule is a legal tool used to characterize property acquired, using both community and separate funds, over a period of time. Harry M. Cross, The Community Property Law in Washington, 61 Wash. L.Rev. 13, 39-49 (rev. 1985). The mortgage rule examines whether both parties concerned were obligated to make payments in order to retain ownership of the disputed asset. If there was no such continuing obligation, then the character of the asset is retrospectively determined to be proportionate to the ratio of separate and/or community funds used to acquire the asset. Id. In this case, petitioner and respondent split equally the down payment for the Walla Walla home. Both signed the promissory note to Sterling Savings Bank to acquire the loan to pay the balance of the home's purchase price. However, petitioner argues since respondent had a nominal income at the time the Sterling Savings Bank loan was *504 secured, the loan was secured on the basis of petitioner's more substantial income. Petitioner relies on the trial testimony of a Sterling Savings Bank loan officer that loan officers weigh heavily an applicant's income when making decisions about loan requests. However, this particular officer was not working at the Sterling Savings Bank when the Zahms requested their Walla Walla home loan. Accordingly, the loan officer could not have known precisely what criteria were considered by the Zahms' approving officer and how the individual loan criterion was weighted. This testimony alone is insufficient to rebut the presumption that this property, acquired during the Zahms' marriage, is community in character. Furthermore, respondent's investment in the purchase of the Walla Walla home was equal with that of the petitioner. Respondent used her separate property (actually, in a slightly greater amount than that offered by petitioner) to pay the Walla Walla home's down payment. Both respondent and petitioner negotiated the financing of the Sterling Savings Bank loan. On the loan application, respondent listed her separate assets as totaling approximately $100,000, nearly double the amount of the bank loan. While respondent's income at the time may have been somewhat inadequate, her asset base was not. The Sterling Savings Bank loan officer that testified at trial did affirm that a loan applicant's assets are part of the criteria considered by bank officers when making decisions on loan requests. Finally, respondent signed the promissory note, making herself equally liable with petitioner for the repayment of the loan to third persons. When both the Zahms signed the promissory note, they created a community debt and the monies borrowed upon that debt were likewise community in character. Given the above formidable facts surrounding the acquisition of the Walla Walla home, petitioner has failed to rebut the presumption that the home was community property. As such, the trial court did not err in characterizing the home as community property. Both the trial court's award of the home to respondent and its award of a $30,000 lien on the home to petitioner were proper. We affirm the Court of Appeals on this issue. Petitioner argues the trial court erred when it characterized the funds in the First Interstate/Idaho Bank account as community property. Petitioner claims monies in that bank account were his separate property. The First Interstate Bank account at dispute is located outside of Washington State. The state law applied to determine the characterization of property is that of the state where the couple resided at the time the property was acquired. In re Marriage of Landry, 103 Wash.2d 807, 810 , 699 P.2d 214 (1985). The Zahms were domiciled in Idaho at the time the disputed First Interstate/Idaho account was established; therefore, Idaho law governs. Property acquired during a marriage is presumed to be community in character under Idaho law. Weilmunster v. Weilmunster, 124 Idaho 227, 232 , 858 P.2d 766 (Ct. App. 1993) (Idaho legal doctrine) (citing Stahl v. Stahl, 91 Idaho 794, 797-98 , 430 P.2d 685 (1967)); In re Marriage of Short, 125 Wash.2d at 870 , 890 P.2d 12 (Washington legal doctrine). The trial court here followed Idaho law in making its determinations regarding the First Interstate/Idaho Bank account. The presumption under Idaho law that the account was community property can be rebutted if the petitioner can prove with reasonable certainty and particularity the account contained commingled, separate property. Houska v. Houska, 95 Idaho 568, 570 , 512 P.2d 1317 (1973). The incident of commingling separate property with community property will not transform the separate property's character into community property. Weilmunster, 124 Idaho at 227 , 858 P.2d 766 (citing Stahl, 91 Idaho at 797-98 , 430 P.2d 685 ). However, if the commingling of separate and community funds cannot be cogently unraveled through the presentation of evidence, Idaho's judicial presumption that the disputed property is community in nature is not rebutted. Martsch v. Martsch, 103 Idaho 142, 146 , 645 P.2d 882 (1982). *505 Petitioner failed to marshal evidence sufficient to overcome the judicial presumption that the monies in the First Interstate/Idaho account are community property. Both petitioner's and respondent's names were on this account. Deposits made to this account resulted in the commingling of community and separate funds. Although petitioner attempted to parse out the alleged separate monies from the community monies in the First Interstate/Idaho Bank account, he was unsuccessful in doing so. There were substantial gaps in his recollection of the bank account's transactions. The trial court's finding that the First Interstate/Idaho Bank account was community property was proper. We affirm the Court of Appeals on this issue. Finally, petitioner argues the trial court erred by awarding respondent maintenance. The standard of review for the appeal of a maintenance award is abuse of discretion. In re Marriage of Mathews, 70 Wash.App. 116, 123 , 853 P.2d 462 (1993). Both Washington statutory law and case law recognize the power of a trial court to award maintenance to either party after the court properly considers all the statutory factors relevant to such a decision. RCW 26.09.080; In re Marriage of Williams, 84 Wash.App. 263, 267-68 , 927 P.2d 679 (1996). The trial court here considered these factors in its ruling and we find no abuse of discretion for its maintenance award to respondent. The trial court gave sufficient and tenable reasons for its application of RCW 26.09.090's fair and equitable factors in its division of the Zahms' property. Drawing from the evidence in the record, the trial court judge, on the record, arrayed the Zahms' incomes, resources, ages, medical conditions, and the ability of petitioner to provide maintenance. These factors were sufficiently adequate and justifiable. Petitioner's social security benefits were an appropriate element for the court to factor into its consideration of respondent's maintenance award for the same reasons contained in the analysis of petitioner's first claim regarding social security benefits. We affirm the Court of Appeals. GUY, C.J., DURHAM, SMITH, MADSEN, ALEXANDER, TALMADGE, SANDERS, and IRELAND, JJ., concur. NOTES [1] In re Marriage of Zahm, 91 Wash.App. at 84-85 , 955 P.2d 412 (quoting RCW 26.09.080) (emphasis added). Case-law data current through December 31, 2025. Source: CourtListener bulk data . A public interest project of Aaron Hall, Attorney at Law © 2026 About Federal Minnesota California New York Texas Terms Data from CourtListener / Free Law Project ↑ \ No newline at end of file diff --git a/.research/zips/1978.zip b/.research/zips/1978.zip new file mode 100644 index 0000000..0ca6a69 --- /dev/null +++ b/.research/zips/1978.zip @@ -0,0 +1,133 @@ + + + + + Leagle.com | A leading provider of copies of primary caselaw from all Federal courts and all State higher courts + + + + + + + +
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    + + diff --git a/README.md b/README.md new file mode 100644 index 0000000..354fe55 --- /dev/null +++ b/README.md @@ -0,0 +1,13 @@ +# Astraea Books — Washington Family Law, In Plain English + +A researched book series on Washington State family law for self-represented +residents. Sources: RCW statutes (app.leg.wa.gov), WashingtonLawHelp.org, +courts.wa.gov, WSBA, Legal Voice — all citations verified. + +Volumes: adoption · child support · committed relationships · custody & +parenting · divorce (dissolution, property division, maintenance, case-law +characterization) · guardianship · mediation/ADR · modification & +enforcement · overview/intake. + +`.research/` and `.case-verify/` hold the verification workpapers. + diff --git a/adoption.md b/adoption.md new file mode 100644 index 0000000..5d7efc6 --- /dev/null +++ b/adoption.md @@ -0,0 +1,102 @@ +For educational purposes only — not legal advice. + +# Washington State Adoption Law — A Practical Guide to Chapter 26.33 RCW + +Adoption in Washington is governed mainly by chapter 26.33 of the Revised Code of Washington (RCW 26.33). Its purpose is to provide stable homes for children, and the guiding principle in every case is **the best interest of the child** (RCW 26.33.010). Adoption cases are heard in **superior court** (RCW 26.33.020(7)), and a petition may be filed in the county where the petitioner lives or where the child lives (RCW 26.33.030). + +## Who Can Adopt and Who Can Be Adopted + +Washington's eligibility rules are broad: + +- **Any person may be adopted, regardless of age or residence** — including adults (RCW 26.33.140(1)). +- **Any person who is legally competent and at least 18 years old may be an adoptive parent** (RCW 26.33.140(2)). The statute sets no minimum income, home ownership, or marital requirements. Married petitioners must both join the petition (RCW 26.33.150(4)); single parents may adopt. The decree must state whether the petitioners are spouses, a stepparent, or a single parent (RCW 26.33.250(1)(c)). +- An adoption **may not be delayed or denied because of the race, color, or national origin** of the adoptive parent or the child, though an agency may consider a child's cultural background when deciding whether a particular placement is in the child's best interest (RCW 26.33.045). + +## The Home Study (Preplacement Report) + +Washington's "home study" is called a **preplacement report**. In most cases, **a child cannot be placed with prospective adoptive parents until a preplacement report has been filed with the court** (RCW 26.33.180). It is prepared by a licensed adoption agency, the Department of Children, Youth, and Families (DCYF), a court-approved individual, or a qualified court employee (RCW 26.33.190(1)). The report must investigate the **home environment, family life, health, facilities, and resources** of the prospective parent and recommend whether the person is fit to adopt (RCW 26.33.190(2)). It must confirm that key topics were discussed with the family: adoption as a lifelong commitment, a child's possible feelings of loss and identity confusion, sibling relationships, telling the child about the adoption, and the child's racial, ethnic, and cultural heritage (RCW 26.33.190(2)(a)–(f)). It must also include a **background check** — state and national criminal records, including fingerprint-based checks of national databases — plus a review of **child abuse and neglect registries** for every state where the applicants or any other adult in the home lived in the prior five years (RCW 26.33.190(3)). Agencies may charge a reasonable fee, which can be reduced or waived for hardship (RCW 26.33.190(4)). After placement, the court orders a **post-placement report** on the child's health, the home, and whether the placement serves the child's best interest, due within 60 days (RCW 26.33.200). + +**Exceptions:** no reports are required when adopting a spouse's child (step-parent adoption) or when the adoptee is 18 or older — unless the court orders otherwise (RCW 26.33.220). + +## The Adoption Process Step by Step + +1. **Petition.** The prospective adoptive parent files a petition in superior court stating the parties' names and addresses, the child's name, gender, and birth information if known, whether the Indian Child Welfare Act applies, and who has custody. Any signed consents are filed with it (RCW 26.33.150). +2. **Preplacement report** (home study) is filed before the child is placed (RCW 26.33.180, RCW 26.33.190). +3. **Placement, then post-placement report** — ordered when the petition is filed and due within 60 days (RCW 26.33.200). +4. **Hearing.** After the reports are filed, the court schedules a hearing. Hearings are **closed to the public and held without a jury**; contested hearings are recorded, and attendees may not disclose identifying information (RCW 26.33.060). If the consents are valid (or properly dispensed with) and the adoption is in the child's best interest, the court **enters a decree of adoption** (RCW 26.33.240). +5. **Decree and birth certificate.** The decree must state the child's original and new names, the adoption type (spouses, stepparent, or single parent), and the information for a new birth certificate (RCW 26.33.250). After the appeal period, the clerk sends a certified copy to the state registrar, who issues a new birth certificate — or forwards it to another state or country's records office if the child was born elsewhere (RCW 26.33.280, RCW 26.33.290). + +Appeals of a decree are decided on an **accelerated (fast) basis**, and later challenges are limited to very narrow grounds — the law intends decrees to be final so families can rely on them (RCW 26.33.260(2)–(4)). + +## Consent and Relinquishment + +**Consent to adoption is required from:** the child, if 14 or older; the child's parents (including an alleged genetic parent) if the child is under 18; the agency or department holding custody, if the child was relinquished to them; and the child's legal guardian (RCW 26.33.160(1)). + +A consent must be **signed under penalty of perjury** and must state that it has no legal effect until a court approves it, that it is revocable before court approval, and that the signer understands their parental rights will be permanently terminated (RCW 26.33.160(4)). A parent or alleged genetic parent must sign in front of an adult witness of their own choosing, identified by name, address, and relationship in the document (RCW 26.33.160(6)). A consent may be valid even if it does not name the adoptive parent (RCW 26.33.160(5)). + +**Relinquishment** is the voluntary surrender of custody (RCW 26.33.020(14)). A parent, the department, or an agency may file a petition to relinquish a child to the department, an agency, or specific prospective adoptive parents, with the parent's written consent attached (RCW 26.33.080). The hearing cannot occur sooner than **48 hours after birth or the signing of the consents, whichever is later**. The court must find the consent validly executed and relinquishment in the child's best interest; if approved, the recipient is appointed legal guardian and the court enters an order terminating the parent-child relationship (RCW 26.33.090). + +**The court must appoint a guardian ad litem for any parent under 18**, who investigates whether the consent was signed voluntarily and with understanding (RCW 26.33.070). + +## Birth Parent Rights and Revoking Consent + +Birth parents have strong procedural protections: + +- A consent **cannot even be presented to the court until 48 hours after it is signed or 48 hours after the child's birth, whichever is later** (RCW 26.33.160(4)(d)). +- A consent is **revocable at any time before the court approves it** — a written revocation delivered or mailed to the court clerk is enough (RCW 26.33.160(2)(a)). +- After approval, revocation is very limited: within **one year**, only for **fraud or duress** by the person or agency requesting the consent, or for the signer's **lack of mental competency** (RCW 26.33.160(3)). A narrow 48-hour rule also applies: if the parent gave notice of revocation to the agency or person who sought the consent within 48 hours of birth, a written revocation delivered to the clerk within 48 hours after that notice is valid even after approval (RCW 26.33.160(2)(b)). + +If a parent has **not** consented, their rights can be ended only through a **termination of parental rights** petition. The parent must get notice of the hearing at least **20 days** in advance in state, or **30 days** out of state; if personal service is impossible, notice by mail and newspaper publication is required (RCW 26.33.310(2)–(3)). Notice must tell the parent they have a right to a lawyer, including a court-appointed lawyer if indigent (RCW 26.33.110(3)(b)(i)), and notices should be in the parent's native language or through an interpreter if needed (RCW 26.33.310(5)). + +Termination requires **clear, cogent, and convincing evidence** that it is in the child's best interest and that the parent has failed to perform parental duties in a way showing substantial lack of regard for parental obligations while withholding consent (RCW 26.33.120(1)). Termination ends all legal rights and duties between parent and child except past-due child support, and the terminated parent gets no notice of the later adoption (RCW 26.33.130). A natural parent who **unsuccessfully** tries to set aside an adoption must pay the adoptive parents' costs and attorney fees, and a parent who consented cannot bring such an action more than **one year** after the court approved the consent (RCW 26.33.360). + +## Step-Parent Adoption + +Adopting your spouse's child is the most common adoption in Washington, and the law makes it easier: + +- The stepparent files the petition and the child's parent **joins in it** (RCW 26.33.150(4)). +- **No home study is required** — preplacement and post-placement reports are waived unless the court orders otherwise (RCW 26.33.220). +- The child's other parent must **consent** (RCW 26.33.160(1)(b)) or have their rights **terminated**. The stepparent may file the termination petition themselves when seeking to adopt their spouse's child (RCW 26.33.100(1)(c)). The other parent's consent can be dispensed with only on clear, cogent, and convincing evidence that the adoption is in the child's best interest — for example, a conviction for rape or incest against the child's other parent (RCW 26.33.170). +- When the decree is entered, the parent who is **not** married to the adopting stepparent and did not join the petition loses all rights and obligations toward the child, except past-due child support (RCW 26.33.260(1)); the parent who joined keeps their rights. + +If the other parent objects or cannot be found, the case becomes contested and the notice and termination rules described above apply (RCW 26.33.110, RCW 26.33.120, RCW 26.33.310). + +## Adopting an Adult + +Washington allows adoption of adults: any person may be adopted regardless of age or residence (RCW 26.33.140(1)), and for an adoptee 18 or older **no home study or post-placement report is required** (RCW 26.33.220). The adoptee's own consent is required (RCW 26.33.160(1)(a)); the parents' consent is required only for adoptees under 18 (RCW 26.33.160(1)(b)). + +The effect is significant: after the decree, the adopted adult becomes the legal heir of the adoptive parent, with inheritance rights equal to a natural child (RCW 26.33.260(1)), and a lawfully adopted child is **not** an heir of their natural parents for inheritance purposes (RCW 11.04.085). Adult adoption is often used to formalize long-standing family relationships, such as a stepparent and adult stepchild. + +## Open vs. Closed Adoption + +Washington law supports both open and closed adoptions. + +- **Open adoption agreements are allowed and can be enforceable.** Parties may agree on contact between the child, birth parents, and siblings. To be enforceable, the terms must be written into a **court order** approved in writing by the parties, with a court finding the contact is in the child's best interest (RCW 26.33.295(1)–(2)). A violation is **not** a ground to undo the adoption, but the order can be enforced in a civil action with attorney fees to the prevailing party (RCW 26.33.295(3)–(4)). + +**In a closed adoption, records stay sealed.** All records of the proceeding are sealed and can be opened only by court order for good cause (RCW 26.33.330). Files are confidential, but **nonidentifying information** (medical history, heritage, education, circumstances of the adoption, etc.) must be disclosed on request to an adoptive parent, adoptee, or birth parent (RCW 26.33.340; RCW 26.33.020(12)). + +Search and reunion rules: + +- An adopted person **21 or older** (or younger with the adoptive parent's permission), or a birth family member after the adoptee turns 21, may ask the court to appoint a **confidential intermediary** to search for and discreetly contact the other party (RCW 26.33.343). +- An adopted person **18 or older** may request a **noncertified copy of their original birth certificate**: for adoptions finalized after October 1, 1993, unless the birth parent filed a valid affidavit of nondisclosure or a contact preference form refusing release; earlier adoptions became available after June 30, 2014. An affidavit of nondisclosure **expires when the birth parent dies** (RCW 26.33.345). +- An adopted adult may file a certified statement with the Department of Health consenting to or refusing release of identifying information and whether they wish to be contacted (RCW 26.33.347). + +## Special Situations + +**Indian children.** Every petition must state whether the child is or may be an Indian child; if so, Washington's Indian Child Welfare Act (chapter 13.38 RCW) and the federal ICWA apply, including notice to the child's tribe (RCW 26.33.040). A parent's consent is valid only if signed more than **10 days after birth** and recorded before a court, and it may be withdrawn for any reason **until the final decree** (RCW 26.33.160(4)(h)); relinquishment and termination hearings also cannot occur sooner than 10 days after birth (RCW 26.33.090, RCW 26.33.110). An adoption does not affect rights or benefits an Indian child derives from tribal descent (RCW 26.33.270). + +**Children from foster care.** For a "hard to place" child, the court considers DCYF's adoption support agreement for payments and services to the family (RCW 26.33.320); DCYF adoption support rules are in WAC 388-27. + +**Out-of-state documents.** A consent, relinquishment, or termination order valid where signed, and consistent with due process, is valid in Washington (RCW 26.33.050). + +**Placement reports.** Before placement, the placing party must provide a complete medical report and a family and social history report, with birth parents' identities kept confidential (RCW 26.33.350, RCW 26.33.380). + +## What the Decree of Adoption Changes + +The decree creates a new legal family: the child becomes, "to all intents and purposes," the legal child and heir of the adoptive parent, with the right to inherit from and through them, and is freed from the rights and obligations of the former parents except past-due child support (RCW 26.33.260(1)). Benefits the child receives from third parties, agencies, the state, or the federal government are not lost (RCW 26.33.270), and a new birth certificate is issued showing the adoptive parents (RCW 26.33.250, RCW 26.33.280, RCW 26.33.290). + +## Getting Help + +Adoption has permanent consequences, and the state courts website does not post adoption forms — it directs families to DCYF and to attorneys. County superior courts (such as King County) publish self-help adoption packets, and WashingtonLawHelp.org offers free plain-language guidance. Because consents, terminations, and decrees are difficult or impossible to undo later, most people have a Washington family law attorney review their case. + +*Sources: chapter 26.33 RCW (verified against the official text on app.leg.wa.gov); RCW 11.04.085; WAC 388-27 (adoption support rules); Washington State Courts adoption forms page (courts.wa.gov).* diff --git a/child-support.md b/child-support.md new file mode 100644 index 0000000..946d3bd --- /dev/null +++ b/child-support.md @@ -0,0 +1,75 @@ +# Washington State Child Support + +For educational purposes only — not legal advice. + +## The Big Picture + +Every parent in Washington has a legal duty to support their children. Child support is set using the **Washington State Child Support Schedule**, codified in chapter 26.19 RCW, which applies in every county, in court and in administrative proceedings, and for both temporary and permanent orders (RCW 26.19.035(1)). The schedule is a formula, not a judge's guess: it uses an **economic table** tied to the parents' combined monthly net income and the number of children (RCW 26.19.011(1), (5); RCW 26.19.020). + +Support can be set two ways: by a superior court judge or commissioner in a family law case, or **administratively by the Division of Child Support (DCS)**, a state agency that uses the same worksheets and schedule. A DCS order is just as enforceable as a court order (WashingtonLawHelp.org, "How is child support set?", reviewed 06/03/2026). + +## How the Calculation Works, Step by Step + +1. **Determine each parent's gross monthly income.** "Gross income" includes essentially everything: salaries, wages, commissions, bonuses, overtime, second jobs, self-employment income, rent, royalties, dividends, interest, trust income, capital gains, pensions, workers' compensation, unemployment, disability insurance benefits, Social Security benefits, and maintenance (alimony) actually received (RCW 26.19.071(3)). + +2. **Deduct allowed expenses to get net monthly income.** Allowed deductions include federal and state income taxes, FICA, mandatory pension plan payments, mandatory union or professional dues, mandatory state insurance premiums, state industrial insurance premiums, court-ordered maintenance actually paid, up to $5,000 per year in voluntary retirement contributions that show a pre-existing pattern, and normal business expenses and self-employment taxes for self-employed people (RCW 26.19.071(5)). + +3. **Combine the two net incomes and look up the economic table.** The table lists a **basic child support obligation per child** for combined monthly net income from $2,200 up through $50,000+ (RCW 26.19.020). For combined net income of $50,000 or less, the table amount is **presumptive** — the court orders it unless a specific, written reason for deviation applies. Above $50,000 per month combined, the court may order more than the table amount, but only with written findings of fact (RCW 26.19.065(3)). + +4. **Split the obligation in proportion to income.** Each parent's share of the basic obligation equals their share of the combined net income. The parent with the child most of the time satisfies their share by having the child live with them; the other parent makes a monthly "support transfer payment" (RCW 26.19.080(1); RCW 26.19.011(10)). + +**Verification and paperwork.** Both parents must provide the preceding two years' tax returns and current pay stubs, and must complete **child support worksheets** under penalty of perjury. The court will not accept incomplete worksheets, and every support order must state both the standard calculation amount and the amount actually ordered, with written findings for any deviation (RCW 26.19.071(2); RCW 26.19.035(3)–(4)). + +## What Counts as Income — and What Doesn't + +Income of a **new spouse or domestic partner**, income of other adults in the household, child support received for other children, gifts, prizes, TANF, SSI, food stamps, and similar public assistance are **excluded** from gross income — though they must still be disclosed. Likewise, overtime or second-job income beyond 40 hours per week can be excluded when it is worked to provide for a current family's needs or to retire past relationship or child support debt, if the court finds the income will stop once the debts are paid (RCW 26.19.071(4)). + +**Imputed income.** A parent who is voluntarily unemployed or voluntarily underemployed can have income **imputed** to them — that is, the court counts income they could be earning. The law gives a priority order: full-time earnings at the current rate of pay; then at a historical rate (using Employment Security data); then a past rate; then 32 hours per week at minimum wage for a parent recently on public assistance or released from incarceration; then full-time at minimum wage for someone with no meaningful earnings history; and finally census median income. Income is **not** imputed to a parent who is gainfully employed full-time unless the court finds they are *purposely* underemployed to reduce support, and it is not imputed to an unemployable parent (RCW 26.19.071(6)). + +## Expenses Beyond the Basic Amount + +The economic table does **not** include health care costs, day care, or certain special expenses. These are added on top and shared in the same proportion as the basic obligation: + +- **Health care costs** — medical, dental, orthodontia, vision, chiropractic, mental health treatment, and prescriptions (RCW 26.19.080(2)). +- **Day care and special child-rearing expenses** — such as tuition and long-distance transportation for visits (RCW 26.19.080(3)). +- **Medical support** — every child support order must require both parents to provide medical support: health care coverage that is accessible and available at reasonable cost, plus cash medical support (a proportionate share of premiums, capped at 25% of the basic support obligation) and a share of uninsured medical expenses (RCW 26.09.105). Coverage can be employer or union insurance or public health coverage (RCW 26.09.105(2); RCW 26.18.170). + +## Deviations From the Standard Calculation + +The standard calculation is presumed correct, but the court may deviate for specific, statutorily recognized reasons — and must state them in written findings. Recognized reasons include a **significant amount of residential time** with the paying parent; children from other relationships; extraordinary debt not voluntarily incurred; special needs of disabled children; special medical, educational, or psychological needs; nonrecurring income (like bonuses or overtime); possession of substantial wealth; significant disparity in living costs; and tax-planning considerations. The parents' mere agreement is **not** by itself a valid reason to deviate (RCW 26.19.075). + +## Limits and Safety Valves + +The schedule contains built-in protections for low- and moderate-income payers (RCW 26.19.065): + +- **Self-support reserve.** Support generally cannot reduce the paying parent's net income below **180% of the federal poverty guideline for a one-person family** — except for the presumptive minimum payment (below). +- **Presumptive minimum.** When a parent's net income is below 180% of the federal poverty guideline, the order is generally **$50 per child per month** unless the parent proves even that would be unjust in their case. +- **45% cap.** A parent's total support obligation for all their children cannot exceed **45% of net income** except for good cause (such as substantial wealth, day care expenses, or special medical/educational needs). +- **Ability to pay.** For a parent with public assistance income or who is incarcerated with no assets, support can be set at $0 in appropriate circumstances (WashingtonLawHelp.org, "How is child support set?"). + +## How Long Does Support Last? + +Child support continues until the child is **emancipated** — which in practice means age 18, unless the order extends it so a child still in high school can **finish high school** (RCW 26.09.170(3), (8)(b)). Support can also be ordered for a **dependent adult child** under RCW 26.09.100 (RCW 26.19.035(1)(f)). + +**Postsecondary (college) support** is possible but is **advisory, not mandatory**: the court decides whether a dependent child's postsecondary educational expenses should be supported, looking at the parents' expectations, resources, and education levels, and the child's aptitudes. To receive it, the child must enroll in an accredited academic or vocational school, actively pursue study, stay in good academic standing, and share academic records with both parents. Support generally ends at the child's **23rd birthday** except for exceptional circumstances, and payments are usually made directly to the school (RCW 26.19.090). + +## Changing (Modifying) a Support Order + +- **Substantial change of circumstances.** Either party can petition to modify support at any time based on a substantially changed circumstance — but voluntary unemployment or underemployment by itself is not a substantial change (RCW 26.09.170(1), (5)). +- **24-month adjustment.** Once 24 months have passed since the order (or the last adjustment), either parent can ask for an adjustment based simply on changes in income or changes in the economic table — no substantial change required (RCW 26.09.170(9)). +- **Other paths.** Modification is also available after one year for severe economic hardship, to extend support through high school, or to add an automatic adjustment provision; and a change of more than 30% that causes hardship can be phased in two equal steps (RCW 26.09.170(8)–(9)). +- **Incarceration.** A parent serving a sentence longer than six months can seek to abate support to $10 per month per order, with restoration available after release (RCW 26.09.170(6)–(7); see also RCW 26.09.320). +- **Procedure.** Modification starts with a petition and worksheets (a $20 filing fee applies to dissolution cases); the responding party has 20 days to answer (60 if out of state) or face default; and the matter is usually decided on affidavits and worksheets rather than live testimony (RCW 26.09.175). + +## Enforcement + +Support orders are enforced through chapter 26.18 RCW and, for cases handled by the state, chapter 74.20A RCW. The **Division of Child Support (DCS)** can collect support through income withholding, intercepts, license actions, and other remedies, and the state is subrogated to the family's right to support when public assistance is paid (RCW 74.20A.030). Parents can also apply to DCS for enforcement services at any time (RCW 26.18.170(5)). All support orders must be registered with the **Washington State Support Registry** with a confidential information form (RCW 26.23.050). + +## Where to Get Help + +- **Washington State Child Support Schedule (WSCSS)** — the definitions, standards, instructions, economic table, and worksheets, free at courts.wa.gov/forms (RCW 26.19.050). +- **Division of Child Support** — dshs.wa.gov/dcs; 1-800-442-KIDS (1-800-442-5437) for enforcement services. +- **WashingtonLawHelp.org** — free guides and fillable Child Support Worksheets and Orders (Northwest Justice Project). +- **CLEAR legal aid hotline** — 1-888-201-1014 (WashingtonLawHelp.org). + +*Sources: RCW 26.19.011, 26.19.020, 26.19.035, 26.19.050, 26.19.065, 26.19.071, 26.19.075, 26.19.080, 26.19.090, 26.09.100 (cross-reference), 26.09.105, 26.09.170, 26.09.175, 26.09.320 (cross-reference), 26.18, 26.18.170, 26.23.050, 74.20A, all verified against app.leg.wa.gov; WashingtonLawHelp.org "How is child support set?" (06/03/2026). Note: RCW 26.19.110 was repealed and is not cited.* diff --git a/committed-relationships.md b/committed-relationships.md new file mode 100644 index 0000000..2c5a029 --- /dev/null +++ b/committed-relationships.md @@ -0,0 +1,94 @@ +# Committed Intimate Relationships (CIRs) in Washington State + +For educational purposes only — not legal advice. + +This book explains Washington's judge-made law of committed intimate relationships: what a CIR is, how courts decide one exists, how property is divided when one ends, and how a CIR differs from marriage. "Committed intimate relationship" (CIR) and the older term "meretricious relationship" describe the same doctrine. + +## What Is a Committed Intimate Relationship? + +A CIR is "a stable, marital-like relationship where both parties cohabit with knowledge that a lawful marriage between them does not exist" (Connell v. Francisco, 127 Wn.2d 339, 346, 898 P.2d 831 (1995), quoting In re Marriage of Lindsey, 101 Wn.2d 299, 304, 678 P.2d 328 (1984)). + +The doctrine grew out of In re Marriage of Lindsey, 101 Wn.2d 299, 678 P.2d 328 (1984). Before Lindsey, property acquired while living together unmarried was presumed to belong to whoever held title — the "Creasman presumption" (Creasman v. Boyle, 31 Wn.2d 345, 196 P.2d 835 (1948)). Courts carved out exceptions (implied partnership, constructive trust, tracing) to avoid unfair results (In re Marriage of Pennington, 142 Wn.2d 592, 599-600, 14 P.3d 764 (2000)). Lindsey overruled Creasman and required courts to "examine the relationship and the property accumulations and make a just and equitable disposition of the property" (Lindsey, 101 Wn.2d at 304, quoting Latham v. Hennessey, 87 Wn.2d 550, 554, 554 P.2d 1057 (1976)). Connell v. Francisco then set the modern framework. + +For decades courts called these relationships "meretricious." In Olver v. Fowler, 161 Wn.2d 655, 657 n.1, 168 P.3d 348 (2007), the Supreme Court recognized the term's negative connotation and substituted "committed intimate relationship," which "accurately describes the status of the parties and is less derogatory" (citing Peffley-Warner v. Bowen, 113 Wn.2d 243, 247 n.5, 778 P.2d 1022 (1989)). Some appellate courts also use the neutral phrase "equity relationship" (In re Meretricious Relationship of Long, 158 Wn. App. 919, 922-25, 244 P.3d 26 (2010); In re Domestic Partnership of Walsh, 183 Wn. App. 830, 834 n.1, 335 P.3d 984 (2014)). + +## This Is Judge-Made (Case) Law, Not Statute + +There is no RCW chapter that creates or defines committed intimate relationships. The doctrine is "a judicial one," developed "in the absence of" statute (Olver v. Fowler, 161 Wn.2d 655, 671 (2007) (Sanders, J., dissenting)). It is a line of Supreme Court and Court of Appeals decisions, mainly Lindsey (1984), Connell (1995), Pennington (2000), and Olver (2007). + +What the legislature has done is different: it wrote marriage law and, in 2008, extended community-property rules to state-registered domestic partnerships (RCW 26.16.030; Laws of 2008, ch. 6, § 604, discussed in Walsh, 183 Wn. App. at 845). The dissolution statute, RCW 26.09.080, applies "in a proceeding for dissolution of the marriage or domestic partnership" — by its terms it does not cover unmarried cohabitants. Courts use RCW 26.09.080 and the separate/community definitions in RCW 26.16.010-.030 only "by analogy" (Connell, 127 Wn.2d at 351). Because the doctrine is judge-made, it can change with new Supreme Court decisions. + +## How Courts Decide a CIR Existed: The Connell Factors + +Connell set out five non-exclusive factors for deciding whether a relationship is a CIR: (1) continuous cohabitation, (2) duration of the relationship, (3) purpose of the relationship, (4) pooling of resources and services for joint projects, and (5) the intent of the parties (Connell, 127 Wn.2d at 346; Pennington, 142 Wn.2d at 601-05). Later courts apply the same five factors (In re Kelly, 170 Wn. App. 722, 733 (2012); Muridan v. Redl, No. 49436-1-II, 413 P.3d 1072 (Wash. Ct. App. Mar. 27, 2018)). + +Key rules about the factors: + +- No single factor decides the case, and the list is not exhaustive (Pennington, 142 Wn.2d at 602). +- The factors must not be applied in a "hypertechnical" way; each case turns on its own facts (Muridan, slip op.; Long, 158 Wn. App. at 926). +- A relationship does not have to be "long term" to qualify, but duration is "a significant factor" (Connell, 127 Wn.2d at 346). A short relationship can qualify only if several substantial factors are present (Lindsey, 101 Wn.2d at 304-05). +- In Pennington, the Supreme Court rejected CIR claims in both consolidated cases: one relationship had sporadic cohabitation and one partner married to someone else for years; the other had equivocal intent and little pooling (Pennington, 142 Wn.2d at 603-05). +- The doctrine applies to same-sex couples. The Court of Appeals "h[e]ld that the meretricious relationship doctrine should be extended to same-sex couples" in Gormley v. Robertson, 120 Wn. App. 31, 83 P.3d 1042 (2004) (Vasquez v. Hawthorne, 145 Wn.2d 103, 33 P.3d 735 (2001), had been vacated and remanded without a merits ruling). +- The doctrine can even apply after both partners die, to divide assets between their estates (Olver, 161 Wn.2d at 657). + +Evidence that supports a CIR finding includes living together continuously, children born or raised together, engagement, shared bank accounts, joint projects, and holding out as a family (see Connell, 127 Wn.2d at 343-45; Muridan, slip op.). + +## Dividing Property When a CIR Ends + +Once a court finds a CIR, it evaluates each party's interest in relationship-acquired property and makes a just and equitable division (Connell, 127 Wn.2d at 349): + +- Only property acquired during the relationship is before the court. Property each partner owned before the relationship — and property received during it by gift or inheritance — stays with its owner (Connell, 127 Wn.2d at 350-51, applying RCW 26.16.010-.030 by analogy). +- All property acquired during the relationship is presumed owned by both partners, regardless of whose name is on the title; the presumption can be rebutted with evidence that the asset was bought with separate-property funds (Connell, 127 Wn.2d at 351-52). +- The division must be "just and equitable," not necessarily 50/50 (Pennington, 142 Wn.2d at 602; Koher v. Morgan, 93 Wn. App. 398, 968 P.2d 920 (1998)). +- A partner's labor is treated like a community asset: earnings during the relationship are relationship property (Koher, 93 Wn. App. at 402). If relationship funds or labor increase the value of one partner's separate property, the relationship may be entitled to reimbursement (Connell, 127 Wn.2d at 352; In re Marriage of Lindemann, 92 Wn. App. 64, 70, 960 P.2d 966 (1998); Walsh, 183 Wn. App. at 842). +- Reviewing courts defer to the trial court: whether a CIR existed is reviewed de novo, but the property division is reviewed for abuse of discretion (Muridan, slip op.; Byerley v. Cail, 183 Wn. App. 677, 684-85, 334 P.3d 108 (2014)). In Muridan, a couple who never married but lived together over six years, had a child, and tried IVF together was found to be in a CIR, and relationship assets were divided as "community-like" property (Muridan, slip op.). + +The unjust-enrichment idea drives the whole doctrine: the point is to prevent one partner from keeping everything at the end of the relationship (Pennington, 142 Wn.2d at 602; In re Estate of Borghi, 167 Wn.2d 480, 483-84, 219 P.3d 932 (2009)). + +## No Palimony and No Maintenance for Unmarried Partners + +Washington does not recognize "palimony" — court-ordered support for an unmarried ex-partner. Maintenance is a statutory remedy limited to dissolution of marriage or domestic partnership: RCW 26.09.090 authorizes maintenance orders "for either spouse or either domestic partner" in dissolution proceedings. In Connell, the Supreme Court stressed that a CIR "is not the same as a marriage" and that marital property laws "do not directly apply" to unmarried couples (Connell, 127 Wn.2d at 349). Courts also held that attorney-fee awards under RCW 26.09.140, available in dissolution actions, are not available in CIR cases (Western Community Bank v. Helmer, 48 Wn. App. 694, 699, 740 P.2d 359 (1987); Foster v. Thilges, 61 Wn. App. 880, 888, 812 P.2d 523 (1991)). + +## The Three-Year Deadline to File + +A claim to divide CIR property is an equitable claim governed by the three-year statute of limitations in RCW 4.16.080(3) (actions "upon a contract or liability, express or implied, which is not in writing"). The clock starts when the CIR ends, not when one partner later "ousts" the other. That rule comes from In re Kelly, 170 Wn. App. 722, 734 (2012), where the court held that a CIR claim "accrues when a CIR ends." Courts may also dismiss stale claims under the doctrine of laches (Kelly, 170 Wn. App. at 731). Practical rule: sue within three years of the breakup or cohabitation ending. + +## Cohabitation Agreements ("Living Together Contracts") + +Unmarried couples can control their own property rights by written agreement. Washington courts have divided property under contract principles when couples made express agreements (Foster v. Thilges, 61 Wn. App. at 884-86; see Pennington, 142 Wn.2d at 599-600). A written agreement can decide who owns what, how expenses are shared, what happens to jointly bought items, and whether any support-like payments will be made at the end. It can also waive or limit CIR claims. Such contracts are generally enforceable like any contract, subject to ordinary defenses (fraud, duress, unconscionability) and to the statute of frauds for real property transfers. WashingtonLawHelp.org (Northwest Justice Project) publishes a plain-language guide and form called the "Living Together Contract" ("Make a Living Together Contract," reviewed June 23, 2025). Signing while the relationship is healthy is the most reliable way to avoid CIR litigation later. + +## How a CIR Differs From Marriage + +Washington does not have common-law marriage; a valid marriage requires a license and ceremony (WashingtonLawHelp.org, "Ending your relationship when you're not married," reviewed Apr. 24, 2026). A CIR is deliberately not marriage: + +- Property: married couples hold community property by statute (RCW 26.16.030), and in divorce all property — community and separate — is before the court (RCW 26.09.080). In a CIR, only community-like property acquired during the relationship is divided (Connell, 127 Wn.2d at 350-51). +- Support: spouses can receive maintenance (RCW 26.09.090); CIR partners cannot. +- Inheritance: a surviving spouse inherits automatically if there is no will (RCW 11.04.015). A CIR partner has no intestate rights; the Supreme Court confirmed an unmarried partner is not a "surviving spouse" for inheritance purposes (Peffley-Warner v. Bowen, 113 Wn.2d at 250). +- Other statutory rights: unmarried cohabitants are not "spouses" for unemployment marital-status benefits (Davis v. Dep't of Employment Sec., 108 Wn.2d 272, 278-79, 737 P.2d 1262 (1987)), wrongful-death claims (Roe v. Ludtke Trucking, Inc., 46 Wn. App. 816, 732 P.2d 1021 (1987)), or dissolution attorney fees (Helmer, 48 Wn. App. at 699). +- Status and deadlines: marriage and registered domestic partnership (RCW 26.60) are formal, registered statuses with full statutory rights; a CIR is a fact-based equitable status with a three-year filing deadline (RCW 4.16.080(3); Kelly, 170 Wn. App. at 734). Registered domestic partners are "treated the same as married spouses" for all purposes under state law (RCW 26.60.015). + +## Practical Takeaways + +- If you lived together in a marriage-like relationship and acquired property together, you may have CIR rights even though you never married (Connell, 127 Wn.2d 339). +- Keep records — who paid for what, joint accounts, and joint projects matter for the Connell factors — and act within three years of the end of the relationship (RCW 4.16.080(3); Kelly, 170 Wn. App. 722). +- You cannot get maintenance or automatic inheritance without marriage or a registered domestic partnership. +- A written cohabitation agreement is the best way to control the outcome in advance (WashingtonLawHelp.org, "Make a Living Together Contract"). If you jointly own real estate but never had a CIR, partition or quiet-title actions may still be available (WashingtonLawHelp.org, "Ending your relationship when you're not married"). + +## Key Cases at a Glance + +- In re Marriage of Lindsey, 101 Wn.2d 299, 678 P.2d 328 (1984) — created the doctrine. +- Connell v. Francisco, 127 Wn.2d 339, 898 P.2d 831 (1995) — defined CIR, listed the five factors, created the community-like presumption. +- In re Marriage of Pennington, 142 Wn.2d 592, 14 P.3d 764 (2000) — factors applied strictly; no CIRs found. +- Gormley v. Robertson, 120 Wn. App. 31, 83 P.3d 1042 (2004) — doctrine extended to same-sex couples. +- Olver v. Fowler, 161 Wn.2d 655, 168 P.3d 348 (2007) — renamed the doctrine "committed intimate relationship"; applies between deceased partners' estates. +- In re Kelly, 170 Wn. App. 722 (2012) — three-year statute of limitations (RCW 4.16.080(3)); claim accrues when the CIR ends. +- In re Domestic Partnership of Walsh, 183 Wn. App. 830, 335 P.3d 984 (2014) — CIR factors and the limits of the community-property analogy restated. +- Muridan v. Redl, No. 49436-1-II, 413 P.3d 1072 (Wash. Ct. App. Mar. 27, 2018) — five factors applied; relationship property divided after a six-plus-year relationship. +- Peffley-Warner v. Bowen, 113 Wn.2d 243, 778 P.2d 1022 (1989) — no intestate inheritance rights for unmarried partners. + +## Sources + +- Washington Supreme Court and Court of Appeals opinions as cited above. +- RCW 26.09.080, 26.09.090, 26.09.140, 26.16.010-.030, 26.16.220, 26.04.010, 26.60.015, 26.60.030, 4.16.080, 11.04.015 (leg.wa.gov). +- WashingtonLawHelp.org (Northwest Justice Project): "Ending your relationship when you're not married" (reviewed Apr. 24, 2026); "Make a Living Together Contract" (reviewed June 23, 2025). +- Stokes Lawrence, "How Washington Recognizes Property Rights Between Unmarried Partners" (2023); University of Washington Law Review, "An Analysis of Cohabitant Property Rights under Connell v. Francisco" (1999). diff --git a/custody-parenting.md b/custody-parenting.md new file mode 100644 index 0000000..69478ec --- /dev/null +++ b/custody-parenting.md @@ -0,0 +1,99 @@ +# Washington State Child Custody and Parenting Plans + +For educational purposes only — not legal advice. + +## The Big Picture + +In Washington, parents in a divorce (dissolution), legal separation, or parentage case usually get a court order called a **Parenting Plan**. Courts here generally do not use the words "custody" and "visitation." Instead, a parenting plan covers two things: (1) a **residential schedule** — which parent the child lives with on given days, including holidays, vacations, and birthdays — and (2) **decision-making authority** — who makes major decisions about the child's education, health care, and religious upbringing (RCW 26.09.184(2), (5)–(6)). + +The governing law is the Parenting Act of 1987, now codified in chapter 26.09 RCW. The state's core policy: "the best interests of the child shall be the standard by which the court determines and allocates the parties' parental responsibilities," and the relationship between the child and each parent "should be fostered unless inconsistent with the child's best interests." The statute is explicit that **residential time and financial support are equally important** parts of parenting arrangements (RCW 26.09.002). + +## What a Parenting Plan Must Contain + +By law, a permanent parenting plan must include provisions for resolving future disputes between the parents, allocation of decision-making authority, and a residential schedule that says in which parent's home each child will reside on given days of the year — including holidays, family birthdays, vacations, and other special occasions (RCW 26.09.184(2), (6)). + +The plan also spells out a **dispute resolution process** other than court action — for example counseling, mediation, or arbitration. Preference is given to carrying out the existing plan, and a parent who misuses or frustrates the process without good reason can be ordered to pay the other parent's attorney fees and financial sanctions (RCW 26.09.184(4)). + +Two practical points built into the law: + +- Either parent may make **emergency decisions** affecting the child's health or safety regardless of how decision-making is allocated (RCW 26.09.184(5)(a)). +- Each parent makes **day-to-day decisions** while the child is with that parent (RCW 26.09.184(5)(b)). +- If one parent violates the plan, that does **not** excuse the other parent from following it; noncompliance can lead to a **contempt of court** finding (RCW 26.09.184(7); RCW 26.09.160). + +## How a Judge Decides the Residential Schedule + +When parents cannot agree, the court builds the residential schedule from the factors in RCW 26.09.187(3). Washington law gives **the greatest weight to one factor: the relative strength, nature, and stability of the child's relationship with each parent**. The other factors are: + +- The parents' agreements (if made knowingly and voluntarily); +- Each parent's past and potential future performance of **parenting functions** — defined in RCW 26.09.004 — including which parent took greater responsibility for the child's daily needs; +- The child's emotional needs and developmental level; +- The child's relationship with siblings and other significant adults, and involvement with school and activities; +- The wishes of the parents and of a child who is mature enough to express reasoned, independent preferences; and +- Each parent's employment schedule, with accommodations consistent with those schedules (RCW 26.09.187(3)(a)). + +Washington does not presume any particular split of time, and the court must not draw presumptions from any temporary parenting plan entered earlier in the case (RCW 26.09.191(2)(a)). + +## Safety Limits and Restrictions + +Parents are responsible for protecting their children's health and well-being, and RCW 26.09.191 requires or allows the court to **limit a parent's residential time** when certain conduct exists. + +**Conduct that requires limits** (RCW 26.09.191(4)(a)–(b)): + +- Willful abandonment that continues for an extended period; +- Physical abuse, or a pattern of emotional abuse, of a child; +- A history of acts of domestic violence (as defined in RCW 7.105.010), an assault causing grievous bodily harm or fear of such harm, or any sexual assault; +- Sexual abuse of a child; and +- Knowingly residing with a person who has engaged in such conduct. + +**Conduct that may lead to limits** (RCW 26.09.191(4)(c)) includes neglect or substantial nonperformance of parenting functions; long-term emotional or physical impairment; long-term drug or alcohol impairment; absence or substantial impairment of emotional ties; "abusive use of conflict" that endangers the child's psychological development; and withholding the child from the other parent for a protracted period without good cause. Note: reporting abuse or seeking a protection order in good faith ("protective actions") does not count as abusive use of conflict (RCW 26.09.191(3)(a), (e)). + +**What the court can order** (RCW 26.09.191(4)(d)): + +- **Supervised visitation**, with a presumption that supervision is by a **professional supervisor** — a lay supervisor is allowed only in limited circumstances (geographic isolation or demonstrated indigency) (RCW 26.09.191(4)(d)(i)(A)); +- **Evaluations or treatment** (for domestic violence perpetration, substance use, mental health, or anger management), with residential time possibly conditioned on completion; +- **No contact** at all, if limits would not adequately protect the child. + +When a parent has committed abandonment, abuse, domestic violence, or assault, the court must also order **sole decision-making** for the other parent and **no dispute resolution except court action** (RCW 26.09.191(5)). Where domestic violence has been found, there is a rebuttable presumption of sole decision-making, and the court must **not require face-to-face mediation** or other interventions that force the parties into the same space (RCW 26.09.191(6)(b)). The court may decline to impose these limits only with express written findings based on **clear and convincing evidence**, addressing specific factors such as current risk and the parent's acknowledgment of past harm (RCW 26.09.191(6)). Cases involving a parent convicted of a sex offense against a child are governed by the stricter rules of RCW 26.09.192. + +## Temporary Orders While the Case Is Pending + +Family law cases can take many months. While the case is pending, either party may ask for **temporary orders** — including temporary support and orders restraining a party from removing a child from the court's jurisdiction, or from disturbing the other party (RCW 26.09.060). Emergency (ex parte) orders issued without notice to the other side may last no more than 14 days, or up to 24 days by court order in specified circumstances (RCW 26.09.060(3)). + +## Moving With a Child (Relocation) + +Washington has a detailed relocation statute, RCW 26.09.405 through 26.09.560, that applies to parenting plans and residential orders. If you want to move with the child, you generally must give the other parent (and anyone else with court-ordered residential time) a **written notice of intended relocation at least 60 days before the move**, served personally or by mail requiring a return receipt. If you did not know the required information in time, notice must be given no more than 5 days after you learn it. The notice must state the reasons for the move, the new address (or as much as is known), and a warning — in exact statutory language — that the other person has **30 days to file and serve an objection**, or the relocation will be permitted (RCW 26.09.440). + +A person objecting must file an objection (a petition to modify the parenting plan or similar proceeding) **within 30 days** of receiving the notice. After an objection is filed, the relocating person generally cannot move the child's principal residence without a court order while the objection period or a scheduled hearing is pending (RCW 26.09.480). + +There is a **rebuttable presumption that the relocation will be permitted**. The objecting person must show the detrimental effect of the move outweighs its benefit, using 11 unweighted factors in RCW 26.09.520 — including the strength of the child's relationships, the good faith of each party, the child's age and needs, the quality of life and opportunities in each location, and the feasibility of the other parent also relocating (RCW 26.09.520). + +## Changing (Modifying) a Parenting Plan + +Final parenting plans are meant to be stable. The court will not modify one unless, based on facts arising since the plan (or unknown at the time), there has been a **substantial change in the circumstances of the child or the nonmoving parent, and the modification is necessary to serve the child's best interests** (RCW 26.09.260(1)). The court keeps the existing residential schedule unless the parents agree, the child has been integrated into the petitioner's family with the other parent's consent, the child's present environment is detrimental, or the nonmoving parent has been found in contempt at least twice in three years for failing to comply with residential provisions or convicted of custodial interference (RCW 26.09.260(2)–(3)). + +There are important exceptions: + +- **Minor adjustments** — changes of no more than 24 days per year, changes driven by the other parent's move or involuntary work-schedule change, or increases up to 90 overnights per year in limited cases — can be made on a showing of substantial change without the full best-interests inquiry (RCW 26.09.260(5)). +- **Relocation-based changes** proceed under the relocation statute without a separate adequate-cause hearing (RCW 26.09.260(6)). +- The court may **reduce or restrict contact** at any time if needed to protect the child, using the limitation criteria of RCW 26.09.191 and 26.09.192 (RCW 26.09.260(4)). + +## Unmarried Parents + +If the parents were never married, legal parentage must generally be established before a parenting plan can be entered. Parentage is established by a voluntary **Acknowledgment of Parentage**, or through a court proceeding to adjudicate parentage under Washington's Uniform Parentage Act, chapter 26.26A RCW. An order determining parentage can include child support and, "on the same basis as provided in chapter 26.09 RCW," residential provisions — though a full parenting plan is not required unless a party asks for one (RCW 26.26B.020(6)–(7)). After an acknowledgment is beyond rescission, a parent can start a judicial proceeding "In re the parenting and support of [child]" to obtain a parenting plan and support order (RCW 26.26B.130). + +## Non-Parents: Guardianship and Visitation + +A person who is **not a legal parent cannot get a parenting plan** in Washington. Since 2021, what used to be called "non-parent custody" is obtained through a **minor guardianship** case under chapter 11.130 RCW, where the court can award a residential schedule for the child. A relative (such as a grandparent) who wants the right to visit a child can separately petition for **nonparental visitation** under chapter 26.11 RCW ("Nonparental child visitation — relatives") (WashingtonLawHelp.org, Parenting Plan Guide, reviewed 07/25/2025). + +## Which Court Can Hear the Case (Jurisdiction) + +Washington can make an initial custody determination only if it is the child's **home state** — generally where the child has lived with a parent or person acting as a parent for the six months before the case is filed — or under limited fallback rules involving significant connections and substantial evidence (RCW 26.27.201). If the child has lived in another state within the last six months, or another state has already issued custody orders, talk to a lawyer before filing (WashingtonLawHelp.org, Parenting Plan Guide). + +## Where to Get Help + +- **WashingtonLawHelp.org** — free plain-language guides and form packets (Northwest Justice Project), including the Parenting Plan Guide and Relocation Guide. +- **courts.wa.gov/forms** — official pattern forms for parenting plans, temporary orders, and modifications. +- **legalvoice.org** (Legal Voice) and **WSBA.org** (Washington State Bar Association) — referral services and legal resources. +- **Washington State CLEAR hotline 1-888-201-1014** — free legal aid intake (WashingtonLawHelp.org). + +*Sources: RCW 26.09.002, 26.09.004, 26.09.060, 26.09.160, 26.09.184, 26.09.187, 26.09.191, 26.09.192, 26.09.260, 26.09.405–26.09.560 (including 26.09.440, 26.09.480, 26.09.520), 26.27.201, 26.26A, 26.26B.020, 26.26B.130, 26.11, 11.130, all verified against app.leg.wa.gov; WashingtonLawHelp.org Parenting Plan Guide (07/25/2025).* diff --git a/divorce-case-law-characterization.md b/divorce-case-law-characterization.md new file mode 100644 index 0000000..3909adc --- /dev/null +++ b/divorce-case-law-characterization.md @@ -0,0 +1,158 @@ +For educational purposes only — not legal advice. + +# Washington State Divorce Case Law: Characterization, Commingling, and Transmutation + +Washington is a community property state. Under RCW 26.16.030, property acquired during marriage — and property acquired before marriage by either spouse's labor — is community property; everything each spouse owned before marriage, plus gifts and inheritances received during marriage, is separate property (RCW 26.16.010). Two working rules flow from these statutes: **property acquired during marriage is presumed to be community property**, and **the character of property — separate or community — is fixed at the date it was acquired**. At divorce, RCW 26.09.080 requires the court to make a "just and equitable" division of all property, both community and separate. The cases below show how Washington courts apply these rules when money gets mixed, titles get changed, and things appreciate. + +## The Acquisition-Time Rule: Character Is Fixed When Property Is Acquired + +### In re Marriage of Chumbley, 150 Wn.2d 1, 74 P.3d 129 (2003) + +**Rule:** Property acquired during marriage has the same character as the funds used to purchase it, and separate property "will remain separate property through changes and transitions, if the separate property remains traceable and identifiable." + +**Facts:** During her marriage, Mary Beckmann earned stock options through her employment. She exercised the options three ways: once with an employer loan, once with money from her separate account, and once by selling part of the purchased stock to pay for the rest. The dispute was whether the resulting stock was community or separate. + +**Why it matters:** Chumbley is Washington's clearest statement that characterization follows the *source of funds* at acquisition. Because the options were community (earned during marriage) and some of the purchase money was separate, the court held the stock "will be divided upon the rates of separate and community contributions" — a proportional, mortgage-rule-style apportionment. It is also the leading modern citation for the traceability rule: changing an asset's form does not change its character if the separate property can still be traced. + +### Borghi v. Gilroy (In re Estate of Borghi), 167 Wn.2d 480, 219 P.3d 932 (2009) + +**Rule:** "The character of property as separate or community is established at acquisition," and spouses "cannot be deprived of their separate property solely because it is used during the marriage to acquire additional property." + +**Facts:** Jeanette Borghi acquired real property before she married Robert Borghi; the property was later titled in both of their names. After her death, her estate and her son Arthur Gilroy fought over whether the property was community or Jeanette's separate property. + +**Why it matters:** Borghi confirms, at the Supreme Court level, that the separate-property right is "as sacred as is the right in their community property" (quoting Guye v. Guye, 63 Wash. 340, 352, 115 P. 731 (1911)). A spouse cannot lose separate property merely because it was used during the marriage — the inquiry is always back to what the property was at acquisition and whether its separate character can be traced. + +### Guye v. Guye, 63 Wash. 340, 115 P. 731 (1911) + +**Rule:** A spouse's right in his or her separate property is as sacred as the right in community property. + +**Why it matters:** Guye is the 1911 foundation for Washington's protection of separate property, still quoted verbatim by the modern Supreme Court in Borghi. It anchors the rule that use of separate property during marriage does not, by itself, convert it into community property. + +### In re Marriage of Mueller, 140 Wn. App. 498, 167 P.3d 568 (2007) + +**Rule:** A legal claim or cause of action is characterized by when the property interest in it was acquired — not merely when the lawsuit was filed. + +**Facts:** The husband was a qui tam (False Claims Act) whistleblower. The dispute was whether he acquired a property interest in the qui tam action when he learned the material facts (before the 2001 marriage) or only when he filed the lawsuit in 2003 (after the marriage). A separate issue concerned an oral property agreement allegedly made during the marriage. + +**Why it matters:** Mueller shows the acquisition-time rule applied to intangible rights — lawsuits, causes of action, and settlements. In a divorce, the timing of when a right *accrued* can determine whether the recovery is separate or community. It also stands for the practical point that characterization disputes are reviewed de novo on appeal while the underlying findings are reviewed for substantial evidence. + +## Gifts, Inheritance, and Rebutting the Community Presumption + +### Cummings v. Anderson, 94 Wn.2d 135, 614 P.2d 1283 (1980) + +**Rule:** The party claiming property is separate can rebut the community-property presumption by showing the asset was acquired by gift or inheritance, with separate funds or separate credit, or from the traceable rents, issues, and profits of separate property. + +**Why it matters:** Cummings lists the standard rebuttal toolkit in Washington. Any client who received a gift or inheritance during marriage, or bought something with pre-marriage money, must be prepared to show the source and the paper trail — the same three routes Cummings identifies. + +### In re Marriage of Skarbek, 100 Wn. App. 444, 997 P.2d 447 (2000) + +**Rule:** A rebuttable presumption arises that property acquired during marriage with separate funds is a gift to the community — but merely depositing separate funds into a joint bank account is *not* an acquisition of property, so no gift presumption attaches to the deposit itself. + +**Facts:** John Skarbek deposited separate funds into a joint account during the marriage. He was able to trace and identify the separate portions of the account, and the court held those remained separate. + +**Why it matters:** Skarbek is the practical commingling-in-bank-accounts case. The key distinction: buying an asset with separate money raises the gift-to-community presumption; parking separate money in a joint account does not. If the separate dollars can still be identified, they stay separate. If they cannot, the asset or account is treated as community. + +## Commingling and Tracing + +### In re Marriage of White, 105 Wn. App. 545, 20 P.3d 481 (2001) + +**Rule:** "Commingling" of separate and community funds may give rise to a presumption that all of the property is community property; the spouse claiming a separate share must then trace the separate funds with sufficient certainty. + +**Facts:** The dispute concerned funds — including a 401(k) account — acquired partly before and partly after the marriage, with separate and community contributions mixed together. + +**Why it matters:** White is the workhorse citation for what happens when the paper trail disappears. Once separate and community money are mixed beyond the point where a court can distinguish or apportion them, the mixed mass loses its separate character and is treated as community. Careful account records are the only defense. + +### Schwarz v. Schwarz, 192 Wn. App. 180, 368 P.3d 173 (2016) + +**Rule:** On dissolution, the trial court must actually characterize each disputed asset — retirement accounts, investment accounts, and similar holdings — as community or separate based on the source of the funds, rather than distributing by label or convenience. + +**Facts:** Susan Champagne challenged the property distribution on dissolution of her marriage to Damian Schwarz, specifically the trial court's characterization and distribution of several retirement and other investment accounts. + +**Why it matters:** Schwarz is the modern appellate reminder that characterization is a legal question courts must decide explicitly. For lawyers, it shows that a decree that skips the tracing analysis — or that assumes an account is all community because it was partly funded with community earnings — is vulnerable on appeal. + +## Transmutation: When Separate Property Becomes Community Property + +Washington recognizes **transmutation**: separate property can become community property when the parties' words or conduct show an intent to make that change — typically a gift of an interest to the community. A change in title alone does not automatically change character, but it can be strong evidence of intent. + +### In re Marriage of Pearson-Maines, 70 Wn. App. 860, 855 P.2d 1210 (1993) + +**Rule:** The character of property (including employee benefits and stock options) is determined when the property is acquired; commingling of separate and community funds may give rise to a presumption that all are community. + +**Facts:** The case involved characterization of employment-related benefits and funds acquired at different points relative to the marriage. + +**Why it matters:** Pearson-Maines is the Court of Appeals case the Supreme Court later relied on in Short for the acquisition-time rule, and it is frequently quoted for the commingling presumption. It bridges the transmutation and tracing doctrines: mixing can shift character, but the starting point is always when the property was acquired. + +### In re Marriage of Olivares, 69 Wn. App. 324, 848 P.2d 1281 (1993) + +**Rule:** Separate property placed into joint title with the other spouse during marriage can transmute into community property where the evidence shows intent to make it community property. + +**Why it matters:** Olivares is commonly cited in the transmutation line of cases for the proposition that joint titling, combined with the parties' conduct, can convert separate property into community property. It is the flip side of the tracing cases: title and conduct matter when the source-of-funds trail is ambiguous. + +### In re Marriage of Sedlock, 69 Wn. App. 484, 849 P.2d 1243 (1993) + +**Rule:** The parties' agreement or course of conduct during the marriage can change the character of property from separate to community (transmutation). + +**Why it matters:** Sedlock, decided the same year as Olivares and Pearson-Maines, rounds out the transmutation trilogy. Together these cases warn that a spouse who keeps separate property segregated and documented preserves its character, while a spouse who treats it as jointly owned may lose the separate label. + +### In re Marriage of Glorfield, 27 Wn. App. 358, 617 P.2d 1051 (1980) + +**Rule:** Separate property may be converted into community property by an effective gift or agreement between the spouses. + +**Why it matters:** Glorfield is the older Court of Appeals authority for transmutation-by-intent. It is still cited for the basic point that characterization is not frozen forever — a valid gift or agreement between spouses changes it. + +## Appreciation of Separate Property + +### In re Marriage of Elam, 97 Wn.2d 811, 650 P.2d 213 (1982) + +**Rule:** "Any increase in the value of separate property is presumed to be separate property," and the presumption "may be rebutted by direct and positive evidence that the increase is attributable to community funds or labors." + +**Facts:** The Elams' dissolution required the court to sort the value of separately owned property that had appreciated during the marriage from any portion of that increase attributable to the marital community's efforts. + +**Why it matters:** Elam sets a deliberately high bar for converting appreciation into community property. The spouse claiming the community share must produce "direct and positive" evidence — speculation that community effort probably helped is not enough. In practice, when community funds or labor *do* increase separate property's value, the community gets a claim for reimbursement, often protected by an equitable lien. + +### In re Marriage of Lindemann, 92 Wn. App. 64, 960 P.2d 966 (1998) + +**Rule:** The rents, income, profits, and increase in the value of separate property are presumed to remain separate; that presumption is overcome only by "direct and positive" evidence that the increase came from community labor or contributions. + +**Why it matters:** Lindemann extends Elam to income streams. Dividends, rents, and passive appreciation of separate assets stay separate in Washington (unlike some community property states). The spouse claiming otherwise must prove the community's causal contribution directly. + +## Stock Options and Other Future Rights + +### In re Marriage of Short, 125 Wn.2d 865, 890 P.2d 12 (1995) + +**Rule:** The characterization of employee stock options as separate or community property under RCW 26.16 depends upon when the options were acquired — options acquired during the marriage are community property. + +**Facts:** Robert Short was a Microsoft employee whose May 1990 and November 1990 stock options were at issue. The trial court apportioned portions of the exercised-option profits and unexercised shares to the wife as community property and gave the rest to Robert as separate. The Court of Appeals reversed in part, holding the options were entirely community property and that the decree's nonmodifiable maintenance provision was invalid; the Supreme Court resolved the characterization question under the acquisition-time rule. + +**Why it matters:** Short is Washington's stock-option case, now applied to RSUs and every other employment-based future right. Options granted during marriage for services performed during marriage are community property even if they vest or are exercised later. The case also produced the practical "time rule"-style apportionment courts use for rights spanning both sides of the marriage. + +## Dividing Separate Property at Divorce + +### In re Marriage of Konzen, 103 Wn.2d 470, 693 P.2d 97 (1985) + +**Rule:** In a dissolution, the trial court may award one spouse's separate property to the other where a just and equitable division requires it; separate property is "no longer entitled to special treatment," and no single factor — such as the character of the property — may be given greater weight as a matter of law. + +**Facts:** Konzen addressed whether a spouse's separate property could be invaded at dissolution, and rejected the argument that such an award was limited to narrowly defined "exceptional" situations. + +**Why it matters:** Konzen is the reason Washington divorce lawyers cannot tell a client, "your separate property is untouchable." RCW 26.09.080 authorizes a just and equitable division of *all* property. The character of the asset still matters enormously — courts generally respect separate property — but it is a factor weighed in the overall division, not a shield. + +### In re Marriage of Littlefield, 133 Wn.2d 39, 940 P.2d 1362 (1997) + +**Rule:** A trial court's property distribution is reviewed for abuse of discretion — "manifestly unreasonable or based on untenable grounds or untenable reasons" — and a disproportionate division must be supported by written findings under RCW 26.09.080. + +**Facts:** The Littlefields' dissolution involved characterization and distribution of the family's assets, including farm property, with a dispute over whether the trial court's award to one spouse was properly supported by findings. + +**Why it matters:** Littlefield is the standard-of-review anchor for every Washington property-division appeal. The spouse challenging a distribution bears a heavy burden on appeal, and trial courts that award property disproportionately must put the supporting findings on the record — without them, the decree is vulnerable to remand. + +## Key Takeaways for Practice + +- **Character is fixed at acquisition** (Chumbley, Borghi); the question is the source of funds, not later titles or forms. +- **Presumptions:** property acquired during marriage is presumed community; separate funds used to buy property during marriage are presumed a gift to the community (Skarbek). +- **Tracing:** separate property survives changes in form only while it remains "traceable and identifiable"; untraceable mixing means community property (Chumbley, White). +- **Transmutation:** separate property can become community through gift, agreement, or conduct showing intent (Glorfield, Sedlock, Olivares). +- **Appreciation:** increases in the value of separate property stay separate unless the other side proves community contribution with "direct and positive evidence" (Elam, Lindemann). +- **Division:** all property — including separate property — is subject to just and equitable division, with written findings required for disproportionate awards (Konzen, Littlefield; RCW 26.09.080). + +## Research Notes + +Citations were verified against CourtListener's Washington Supreme Court and Court of Appeals records (names, docket numbers, reporters, and dates) and cross-checked against Leagle's Washington case archive. Holdings were verified against the language of the opinions themselves or against quotations of the opinions in later Washington appellate decisions and Supreme Court filings (courts.wa.gov). Primary full-text sources used include the Municipal Research and Services Center archive (courts.mrsc.org), CourtListener, and Washington court filings. Cases proposed for this book whose subject matter did not match this topic — such as In re Marriage of Kovacs, 121 Wn.2d 795 (1993), which concerns residential placement of children rather than property characterization — were excluded. diff --git a/divorce-case-law-division.md b/divorce-case-law-division.md new file mode 100644 index 0000000..1188225 --- /dev/null +++ b/divorce-case-law-division.md @@ -0,0 +1,143 @@ +For educational purposes only — not legal advice. + +# Washington Divorce Case Law: Dividing Property — the "Just and Equitable" Standard + +Washington is a community property state, but at divorce the labels "community" and "separate" only set the table. Under RCW 26.09.080, the court must make "such disposition of the property and the liabilities of the parties, either community or separate, as shall appear just and equitable," without regard to marital misconduct, considering at least four factors. This book collects the published Washington cases that show how the appellate courts actually apply that standard to the hardest division questions: unequal awards, characterization, professional goodwill, retirement benefits, businesses, and debt. Every citation below was verified against the published opinion text. + +## The Standard and Its Four Factors + +The statute directs the court to consider: (1) the nature and extent of the community property; (2) the nature and extent of the separate property; (3) the duration of the marriage; and (4) the economic circumstances of each spouse at the time the division becomes effective. The trial court has broad discretion, and its division is reversed only for a manifest abuse of discretion — for example, when the decree leaves a patent disparity in the parties' economic circumstances. + +### In re Marriage of Konzen, 103 Wn.2d 470, 693 P.2d 97 (1985) + +**Holding:** The trial court had the authority to award the wife a share of the husband's military retired pay even though the pay accrued entirely before the marriage and was his separate property, and doing so was not an abuse of discretion. + +**Facts:** This was a second marriage for both spouses. Mr. Konzen had already retired from a 25-year Navy career and was receiving about $1,653 per month in military retired pay. Both parties were unemployed at trial, but the court found Mr. Konzen had a substantially and disproportionately greater earning capacity — he held undergraduate and master's degrees and had worked as a manager. + +**Why it matters:** Konzen is the clearest statement that the just-and-equitable standard reaches separate property. The court may invade one spouse's separate assets when fairness and the parties' comparative economic circumstances require it. + +### Friedlander v. Friedlander, 80 Wn.2d 293, 494 P.2d 208 (1972) + +**Holding:** All property, community and separate, is before the trial court for distribution; the court affirmed awarding the wife substantially all of the community property while the husband kept his separate property, after striking down a prenuptial agreement the wife had signed without independent advice. + +**Facts:** The husband's separate property consisted principally of his interests in the "Friedlander family enterprises," valued at about $1,041,183 when the marriage began. A prenuptial agreement the parties signed before marrying was held void in its inception because the wife received no independent advice and the agreement was unfair. + +**Why it matters:** Decided under the former divorce statute but still cited today (for example, in Olivares, below) for the rule that the division power covers every asset before the court, and that characterization does not dictate the result. + +## Unequal Division Is Allowed + +Equal division is not required. The longer the marriage, the more likely a disproportionate division will be upheld — especially when one spouse is older, semi-retired, or in ill health and the other is employable. + +### In re Marriage of Rockwell, 141 Wn. App. 235, 170 P.3d 572 (2007) + +**Holding:** Affirmed a 60/40 division of the wife's federal pension in a 26-year marriage, including the trial court's consideration of the husband's future earning capacity and a $159,464 adjustment for Social Security benefits the wife would never receive; reversed only the trial court's use of the "subtraction method" to characterize and value the pension. + +**Facts:** Peter and Carmen Rockwell were married from 1978 to 2004. Carmen spent 16 years in the federal civil service before the marriage and 24 more during it, retiring as a GS-15 executive under the Civil Service Retirement System — a pension that stands in place of Social Security. Peter was laid off at 48 and stopped seeking work in 2002. The trial court found the pension 92 percent community and 8 percent separate, then divided the community portion 60 percent to Carmen and 40 percent to Peter. + +**Why it matters:** A blueprint for long-marriage divisions: unequal awards survive review, earning capacity and Social Security circumstances are legitimate factors, and pension valuation methods (here, the subtraction method) are scrutinized on appeal. + +### In re Marriage of White, 105 Wn. App. 545, 20 P.3d 481 (2001) + +**Holding:** When a spouse spends separate inheritance money to pay debts on community property, the assets remain community property — character is fixed at acquisition — but the contribution is a factor that can justify an unequal division. The trial court reached the right result for the wrong reasons, so the case was remanded for reconsideration. + +**Facts:** Carol and Frank White married in 1973, separated in 1997. In 1993–94, Carol used $30,511 of an inheritance to pay off the family car ($4,000) and the family home ($26,511). The trial court characterized the $30,511 as still Carol's separate property and awarded her the first $26,511 of home value and the first $4,000 of car value. + +**Why it matters:** The leading case on separate funds spent on community assets. There is no automatic transmutation and no burden-of-proof game about intent to make a gift; instead, the contribution is weighed as a distribution factor — here labeled an "unusually significant contribution." + +## Characterization: Community vs. Separate + +Before dividing, the court characterizes each asset. The source of the property and the date of acquisition guide the analysis, but the final division must be fair under all the circumstances. + +### In re Marriage of Olivares, 69 Wn. App. 324, 848 P.2d 1281 (1993) + +**Holding:** Affirmed the trial court's characterization of a promissory note assigned to both spouses by the husband's parents, and of a car titled in the wife's name, as community property — even though the marriage lasted under two years. + +**Facts:** Third marriages for both parties; they married in December 1988 and separated in August 1990. The couple lived on Stephen's pre-marriage assets and gifts and loans from his parents. Through escrow, his elderly parents assigned a promissory note/deed of trust worth about $235,000 ($2,000 per month for 27 years), and the escrow agent put Theresa's name on the documents; payments went to an account bearing both spouses' Social Security numbers. Stephen also bought a 1968 Ford Mustang on his separate credit but placed the title in Theresa's name. The court found the note a gift to both spouses and the car a gift to Theresa, and awarded one-half of the note to each. + +**Why it matters:** Gift characterization turns on donative intent shown by conduct — here, putting property in both names. The short duration of the marriage did not make the division an abuse of discretion. + +### In re Marriage of DewBerry, 115 Wn. App. 351 (2003) + +**Holding:** An oral agreement to treat income earned during marriage as separate property is enforceable where the trial court finds, by clear, cogent, and convincing evidence, that the parties fully performed their separate-property agreement during the marriage. + +**Facts:** The DewBerrys agreed that their earnings would remain separate. Both were professionals — Carla left Arthur Andersen to become an associate in a Seattle law firm while George worked. The trial court found full performance of the agreement, characterized the property acquired during marriage accordingly, and allocated each spouse's separate property to the spouse who acquired it. The Court of Appeals affirmed the property division. + +**Why it matters:** Wages earned during marriage are not inevitably community property. A fully performed separate-property agreement — even an oral one — can change the characterization of everything earned during the marriage. + +### In re Marriage of Brown, 100 Wn.2d 729, 675 P.2d 1207 (1984) + +**Holding:** Recovery for a personal injury inflicted on a married person by a third party is the separate property of the injured spouse, except to the extent the recovery compensates the community for lost wages (which would have been community property) or for injury-related expenses the community incurred. + +**Facts:** Ronna Brown had a potential tort recovery from an injury sustained during her marriage. The Court of Appeals held the potential recovery was community property; the Supreme Court reversed and reinstated the trial court's disposition consistent with its new characterization rule. + +**Why it matters:** The controlling characterization rule for personal-injury claims in a property division, and the source of the "wage-replacement" concept applied later in Brewer. + +### In re Marriage of Brewer, 137 Wn.2d 756, 976 P.2d 102 (1999) + +**Holding:** Monthly payments to a permanently disabled spouse under private disability insurance policies after dissolution are the separate property of the disabled spouse — even though the policies were acquired during the marriage and premiums were paid from community funds before being waived. + +**Facts:** Michael Brewer became permanently disabled during the marriage. After dissolution, he received monthly disability benefits under policies bought during the marriage with community premiums. Applying the Brown wage-replacement rule, the Supreme Court affirmed in part and reversed in part, treating the post-dissolution benefits as compensation for the disabled spouse's future wage loss rather than as a divisible asset. + +**Why it matters:** Distinguishes wage-replacement disability benefits (separate, not divisible) from other insurance proceeds, and remains the case to cite whenever disability income appears in a dissolution. + +### In re Marriage of Zahm, 138 Wn.2d 213, 978 P.2d 498 (1999) + +**Holding:** A trial court may not characterize a spouse's Social Security benefits as community property, because federal law makes those benefits indivisible and not subject to reassignment; the error was harmless here because the division was otherwise just and equitable, so the Court of Appeals was affirmed. + +**Facts:** The Zahms married in 1978, divorced in 1987, reunited, and permanently separated in 1995. In the final dissolution, the trial court characterized two bank accounts and the Walla Walla home as community property and also listed the husband's Social Security benefits as community property. The Court of Appeals agreed the Social Security characterization was error but harmless. + +**Why it matters:** Social Security benefits cannot be treated as a divisible asset — though they may still inform the economic-circumstances analysis under RCW 26.09.080. + +## Professional Goodwill and Education + +### In re Marriage of Fleege, 91 Wn.2d 324, 588 P.2d 1136 (1979) + +**Holding:** The goodwill of a professional practice is an asset subject to division as part of the community property, even if it is not readily salable — the important consideration is whether the goodwill has value to the professional. + +**Facts:** After a 32-year marriage, the husband's dental practice produced net profits of $106,452.61 in 1975. The wife, a trained dietician who had not worked during the marriage, presented two CPAs who valued the practice with a goodwill component; the trial court refused to include goodwill as a divisible asset. + +**Why it matters:** Fleege established that professional goodwill is divisible property in Washington, and every later goodwill case builds on it. + +### In re Marriage of Hall, 103 Wn.2d 236, 692 P.2d 175 (1984) + +**Holding:** Professional goodwill is divisible, but the trial court must state on the record which factors and valuation method it used. Future earning potential is not a separate asset that offsets goodwill; instead, it is a substantial factor in making a just and equitable division. Reversed and remanded. + +**Facts:** Both spouses were physicians. The husband, in private practice, was found to have goodwill worth $70,000; the wife, a salaried professor, was found to have none. The Supreme Court held the bare finding unsupported without articulated valuation factors and methods, and declined to treat the wife's future earning potential as an asset. + +**Why it matters:** The framework for valuing goodwill (including the methods the opinion illustrates) and the rule that earning capacity is weighed as a factor, not valued as an asset. + +### In re Marriage of Washburn, 101 Wn.2d 168, 677 P.2d 152 (1984) + +**Holding:** Where one spouse supports the other through professional school in the mutual expectation that the community will enjoy the resulting financial benefit, but the marriage ends before that benefit is realized, the supporting spouse's contribution must be considered — as a factor in dividing property under RCW 26.09.080 or in awarding maintenance. + +**Facts:** The Washburns married in 1971 while juniors in college; the wife worked while the husband pursued professional education, and the marriage dissolved before the expected payoff. In the consolidated Gillette case, the trial court had valued the wife's contribution to her husband's education and added a $19,000 lump-sum award, which was affirmed. + +**Why it matters:** The remedy for education contributions when there is no professional goodwill yet to divide. + +## Pensions, Retirement, and Military Benefits + +### In re Marriage of Bulicek, 59 Wn. App. 630, 800 P.2d 394 (1990) + +**Holding:** Pension benefits are property rights in the nature of deferred compensation and may be divided even when not yet in pay status; the trial court did not abuse its discretion in awarding the wife a percentage of the GTE pension on an as-received basis, or in its maintenance award. + +**Facts:** George and Janet Bulicek married in 1963 and separated 22 years later. George's GTE pension was partly community (service during marriage) and partly separate (a 40-month pre-marriage service credit). At trial Janet earned about $720 per month and George about $2,500; Janet had serious health problems. The court divided the pension by a percentage payable as received, and awarded maintenance. + +**Why it matters:** Shows a mixed-character pension being divided by percentage on an as-received basis, and how retirement division and maintenance work together to reach a fair result. + +### In re Marriage of Kraft, 119 Wn.2d 438, 832 P.2d 871 (1992) + +**Holding:** Military disability retirement pay may not be treated as an asset of the community in a dissolution property division, under the federal rule of Mansell v. Mansell; the trial court's division was reversed and remanded. + +**Facts:** After a marriage of more than 20 years, the trial court included the husband's military disability retirement pay as a community asset in the distribution. The Supreme Court held that consideration of the disability pay was improper and remanded for reconsideration of the property distribution without it. + +**Why it matters:** The line between military retired pay (which, per Konzen, can be distributed) and military disability pay (which, per federal law, cannot be treated as a divisible asset). + +## Dividing Debts and Liabilities + +The statute governs "the property and the liabilities of the parties, either community or separate," so debt division is part of the same just-and-equitable exercise — no separate, mechanical rule applies. The cases above show the working principles: + +- **Debts paid with separate funds** do not change the character of the assets they secured (White), but the paying spouse's contribution is a factor supporting an unequal award in that spouse's favor. +- **Community debts and obligations are weighed with the assets** in the overall division — in Rockwell, the trial court considered the community debts alongside the pension, retirement accounts, and tangible property before approving a 60/40 split. +- **Separate property can be awarded across the line** (Konzen, Friedlander) when needed to balance the economic circumstances of the parties, including responsibility for liabilities. + +A final practical note: these decisions were verified against the published opinions as they existed at the time of writing. Case law changes — before relying on any case here, check its current status and read the full opinion. diff --git a/divorce-case-law-maintenance.md b/divorce-case-law-maintenance.md new file mode 100644 index 0000000..99a9f0b --- /dev/null +++ b/divorce-case-law-maintenance.md @@ -0,0 +1,142 @@ +# Washington State Divorce Case Law — Spousal Maintenance & Attorney Fees + +For educational purposes only — not legal advice. + +## About this book + +This book explains Washington State divorce case law on **spousal maintenance** (often called alimony) and **attorney-fee awards**, using real appellate decisions. Every case was verified against the actual published opinion text, including its exact court, volume, reporter, page, and year. Citations follow standard Washington form: *In re Marriage of Smith*, 123 Wn.2d 456 (1999) (Supreme Court) or 123 Wn. App. 456 (1999) (Court of Appeals). + +The governing statutes are **RCW 26.09.090** (maintenance), **RCW 26.09.170** (modification), and **RCW 26.09.140** (attorney fees). + +## The framework: six factors, no formula + +Washington has **no formula** for maintenance. A court "may" award maintenance to either spouse "in such amounts and for such periods of time as the court deems just," **without regard to marital misconduct**, after considering all relevant factors (RCW 26.09.090(1)): (1) the requesting spouse's financial resources, including property received in the division, and ability to meet needs independently; (2) time needed for education or training to find appropriate employment; (3) the standard of living during the marriage; (4) the duration of the marriage; (5) the requesting spouse's age, physical and emotional condition, and financial obligations; and (6) the other spouse's ability to pay while meeting their own needs. + +Two rules frame everything. Maintenance is **not a matter of right** — its purpose is to support a spouse until that spouse can earn their own living or otherwise becomes self-supporting (*In re Marriage of Luckey*, 73 Wn. App. 201, 868 P.2d 189 (1994)). And the trial court's discretion is **wide**; the only limitation on amount and duration is that the award must be just in light of the factors (*In re Marriage of Bulicek*, 59 Wn. App. 630, 800 P.2d 394 (1990)). + +## The landmark maintenance cases + +### In re Marriage of Washburn — maintenance as a "flexible tool" + +**In re Marriage of Washburn, 101 Wn.2d 168, 677 P.2d 152 (1984)** (Supreme Court, en banc). **Holding:** When one spouse supports the other through professional school expecting to share the resulting benefit, and the marriage ends first, the supporting spouse's contribution **must be considered** in dividing property (RCW 26.09.080) or in awarding maintenance (RCW 26.09.090). + +**Facts:** In two consolidated cases, wives worked full time while their husbands attended veterinary school — Mrs. Washburn from 1974 to 1978, Mrs. Gillette through her husband's 1982 degree. The student husbands kept the degrees and future earning power; the supporting wives had little to show for their sacrifice. + +**Why it matters:** Washburn is the most-cited maintenance case in Washington because of its famous language: maintenance "is not just a means of providing bare necessities, but rather a flexible tool by which the parties' standard of living may be equalized for an appropriate period of time." That principle drives the cases that follow. + +### In re Marriage of Sheffer — standard of living is a paramount concern + +**In re Marriage of Sheffer, 60 Wn. App. 51, 802 P.2d 817 (1990)** (Court of Appeals, Division One). **Holding:** In a long marriage where one spouse sacrificed a career for the family, the trial court must carefully weigh the marital standard of living and the parties' post-dissolution economic positions; failing to do so requires reversal. + +**Facts:** After 30 years of marriage, Alfred earned about $4,900 per month, while Beverly — who had quit work as a secretary by agreement to raise their four children — would have about $844 per month once her three-year award expired. + +**Why it matters:** Sheffer applies Washburn's "flexible tool" principle to a traditional long marriage, holding that "the standard of living of the parties during marriage and the parties' postdissolution economic condition are paramount concerns." The court reversed and remanded for a revised maintenance award, and awarded the wife appellate fees based on the income disparity. + +### In re Marriage of Bulicek — duration can reach retirement + +**In re Marriage of Bulicek, 59 Wn. App. 630, 800 P.2d 394 (1990)** (Court of Appeals, Division One). **Holding:** A maintenance award of $500 per month for one year, then $400 per month until the husband retired, was within the trial court's wide discretion in a 22-year marriage where the wife was in ill health. + +**Facts:** George (52, healthy) earned about $2,500 per month; Janet (46, with numerous health problems) earned about $720 plus a $169 disability payment. + +**Why it matters:** Bulicek rejects the idea that maintenance must always be brief and rehabilitative — Janet would "likely never achieve the postdissolution economic level of George." Bulicek also states the basic fee rule: fees rest on the requesting spouse's **need** and the other spouse's **ability to pay**, and "neither party is entitled to attorney's fees as a matter of right." + +### In re Marriage of Luckey — no right to maintenance; discretion is wide + +**In re Marriage of Luckey, 73 Wn. App. 201, 868 P.2d 189 (1994)** (Court of Appeals, Division Three). **Holding:** Denying maintenance beyond the first year of separation was not an abuse of discretion where the property division favored the wife and she received substantial support. + +**Facts:** Robert and Patricia Luckey were married 14 years; Robert was a physician. The trial court valued his practice's goodwill at zero and denied Patricia maintenance beyond what was paid in the first year of separation. + +**Why it matters:** Luckey collects the core standards: maintenance "is not awarded as a matter of right"; its purpose is support until the recipient becomes self-supporting; and the trial court's discretion is "wide," limited only by the requirement that the award be just under the statutory factors. The denial was affirmed because the property division favored the wife — $22,800 in first-year support, $785 per month child support, and a $21,000 payment. + +### In re Marriage of Muhammad — fault is off-limits + +**In re Marriage of Muhammad, 153 Wn.2d 795, 108 P.3d 779 (2005)** (Supreme Court, en banc). **Holding:** A trial court abuses its discretion when it considers marital fault — here, domestic violence allegations — in dividing property; the Supreme Court reversed and ordered a new trial before a new judge. + +**Facts:** Cherry Gilbert (formerly Muhammad) and Dawud Muhammad married after about 20 months of cohabitation and separated in April 2001 amid domestic violence allegations against Muhammad, a deputy sheriff. The trial court appeared to weigh the fault allegations in dividing property. The Court of Appeals found no improper consideration of fault (119 Wn. App. 166, 79 P.3d 483 (2003)); the Supreme Court disagreed. + +**Why it matters:** Muhammad is the leading modern statement of the **no-fault principle**. Maintenance awards are likewise made "without regard to marital misconduct" (RCW 26.09.090(1)), so Muhammad keeps fault — however serious — out of the award. The remedy was severe: a new trial with a new judge. + +### In re Marriage of Mansour — no written findings required on every factor + +**In re Marriage of Mansour, 126 Wn. App. 1, 106 P.3d 768 (2005)** (Court of Appeals, Division One). **Holding:** RCW 26.09.090 requires the court to **consider** the statutory factors, but not to make specific written findings on each one; denying maintenance was not an abuse of discretion where the wife received substantial home-sale proceeds. + +**Facts:** Cindy and Ghassan Mansour divorced after a long marriage. The trial court awarded the wife mortgage payments until the house sold and two months of $1,500 relocation payments. + +**Why it matters:** Mansour gives trial courts flexibility — no item-by-item factor findings are required — while confirming abuse-of-discretion review. It also states the fee standard: the court "must balance the needs of the spouse requesting them with the ability of the other spouse to pay," and may deny fees when the requesting spouse has resources (here, house proceeds). On appeal, the wife won fees after showing both merit and need. + +### In re Marriage of Rockwell — earning capacity counts, but is not divisible property + +**In re Marriage of Rockwell, 141 Wn. App. 235, 170 P.3d 572 (2007)** (Court of Appeals, Division One). **Holding:** In a 26-year marriage, a 60/40 property split favoring the older, retired, ill wife over the younger, employable husband was not an abuse of discretion; a court may compare the parties' future earning capacity as a factor, though it may not divide earning capacity itself as an asset. + +**Facts:** Peter Rockwell, an engineer who stopped working after a 1999 layoff, challenged the 60/40 division in favor of Carmen, a retired federal executive drawing a substantial pension in lieu of Social Security. + +**Why it matters:** Rockwell connects maintenance doctrine to property division. Washington courts aim to put parties "in roughly equal financial positions for the rest of their lives," and earning capacity — age, health, training, work history — is a legitimate factor in that assessment, so long as it is not converted into a divisible asset. The court did reverse the pension-valuation method used: even a fair result needs a correct methodology. + +### In re Marriage of Anthony — a modern application + +**In re Marriage of Anthony, 9 Wn. App. 2d 555, 446 P.3d 635 (2019)** (Court of Appeals, Division One). **Holding:** The decision to award maintenance to a long-time homemaker was affirmed, but the case was remanded because the trial court set the award without making findings on the parties' incomes or addressing the statutory factors in writing. + +**Facts:** Joseph and Penny Anthony married in 1987. Penny, who never finished eighth grade, stayed home with their four children while Joseph served 22 years in the Marine Corps and later drove trucks, grossing about $7,807 per month. + +**Why it matters:** Anthony shows the current appellate expectation: maintenance amounts must be traceable to actual income findings and the RCW 26.09.090 factors. The court also directed the trial court to address a pending RCW 26.09.140 fee request on remand. + +## Duration: how long can maintenance last? + +Duration is not set by formula. The governing question is what is "just" under the factors. + +- **Short, rehabilitative awards** fit cases where education or training will make the recipient self-supporting (RCW 26.09.090(1)(b)). In *Washburn*, the Court spoke of allowing the supporting spouse "to share, temporarily" in the student spouse's earnings. +- **Long awards** fit long marriages where the recipient will never catch up. *Bulicek* approved $400 per month **until the husband retired**. In *Sheffer*, a three-year award was reversed because it ignored the recipient's permanent disadvantage. +- **Reconciliation does not end maintenance.** In *In re Marriage of Moody*, 137 Wn.2d 979, 976 P.2d 1240 (1999), the Supreme Court held that reconciliation did not invalidate a legal separation decree, its maintenance provisions, or a later agreed order extending payments. +- **Automatic termination events.** Under RCW 26.09.170(2), unless the parties agree otherwise in writing, future maintenance ends automatically on the death of either party or the recipient's remarriage (or registration of a new domestic partnership). + +## Modification and termination + +A maintenance award can be modified, but only prospectively and only on a showing of a **substantial change of circumstances** since the decree (RCW 26.09.170(1)). + +- **Lambert v. Lambert, 66 Wn.2d 503, 403 P.2d 664 (1965)** (Supreme Court). **Holding:** A self-induced income decline is not a changed circumstance justifying modification. The optometrist husband voluntarily curtailed his earning capacity after the divorce; the Supreme Court reversed the reduction and reinstated the original award. The rule remains foundational: modification requires a change occurring after the decree that was not — and could not have been — litigated in the original action; a "voluntary reduction in income or self-imposed curtailment of earning capacity, absent a substantial showing of good faith," will not support modification. +- **In re Marriage of Spreen, 107 Wn. App. 341, 28 P.3d 769 (2001)** (Court of Appeals, Division Two). **Holding:** Worsened mental health (bipolar disorder making the wife unemployable) was a changed circumstance justifying an extension, but limiting it to one year because she had received maintenance "long enough" and government assistance was available was an abuse of discretion. Spreen requires actual application of the RCW 26.09.090 factors — arbitrary time caps and speculation about public assistance, with no evidence of what programs exist, are improper. +- **In re Marriage of Drlik, 121 Wn. App. 269, 87 P.3d 1192 (2004)** (Court of Appeals, Division Three). **Holding:** A court may **suspend** (not only modify or terminate) maintenance under RCW 26.09.170, but may not suspend it indefinitely on an unsupported finding that the payer might return to work. After a 38-year marriage, the husband paid $3,300 per month until age 70; stricken with brain cancer, he sought relief. The suspension authority was proper, but the indefinite, speculative basis required remand. +- **Moody** (above) adds that the parties can agree to modify maintenance terms post-decree, and such agreed orders bind the parties even after reconciliation. + +## Attorney fees in divorce + +Attorney-fee awards in dissolution are governed by **RCW 26.09.140**, which allows a court to order one party to pay the other's reasonable attorney fees "after considering the financial resources of both parties." + +### The basic standard: need and ability + +The trial court "must balance the needs of the spouse requesting them with the ability of the other spouse to pay" (*Mansour*, quoting *In re Marriage of Stenshoel*, 72 Wn. App. 800, 866 P.2d 635 (1993)). Fees are not a matter of right (*Bulicek*). The decision is discretionary; the challenger must show it was clearly untenable or manifestly unreasonable. + +### In re Marriage of Knight — how fee awards are built and reviewed + +**In re Marriage of Knight, 75 Wn. App. 721, 880 P.2d 71 (1994), review denied, 126 Wn.2d 1011 (1995)** (Court of Appeals, Division Two). **Holding:** A $149,000 fee award was affirmed where the court indicated its method, balanced needs against ability to pay, and considered the case's complexity. + +**Facts:** The trial court valued Judy Knight's business (Ramtha Dialogues) with $792,000 of goodwill going to her husband, and awarded him roughly half his fees given the large economic disparity and the vigorous defense he faced. + +**Why it matters:** Knight collects the mechanical rules: the court **must indicate on the record the method used to calculate the award**, must balance need against ability to pay, and should weigh (1) the factual and legal questions involved, (2) the time necessary to prepare and present the case, and (3) the amount and character of the property involved (*Abel v. Abel*, 47 Wn.2d 816 (1955)). + +### In re Marriage of Van Camp — the lodestar formula is not required + +**In re Marriage of Van Camp, 82 Wn. App. 339, 918 P.2d 509 (1996)** (Court of Appeals, Division Three). **Holding:** Dissolution courts are not required to use the lodestar method (hours × reasonable rate); they may instead apply the traditional dissolution factors — need, ability, and equity. + +**Facts:** The wife's lawyers sought about $60,000 in fees; the husband's expert said $12,000–$13,500 was reasonable. The trial court reviewed time records, awarded roughly $37,000, and was affirmed. + +### Fees based on intransigence (bad conduct) + +Separate from need-and-ability fees, a court may award fees caused by a party's **intransigence** — foot-dragging, obstruction, or unnecessary motions that make the litigation unduly difficult. + +- **In re Marriage of Greenlee, 65 Wn. App. 703, 829 P.2d 1120 (1992)** (Court of Appeals, Division One). **Holding:** When intransigence is established, **the requesting spouse's financial resources are irrelevant** — the award is an equitable remedy. The husband's obstructionist refusal to cooperate in refinancing the former family home justified fees for the wife, who had been forced to court to enforce the decree. +- **In re Marriage of Mattson, 95 Wn. App. 592, 976 P.2d 157 (1999)** (Court of Appeals, Division Two). **Holding:** Fee awards were affirmed on both RCW 26.09.140 need/ability grounds and intransigence grounds, where the husband's income "increased with each round of investigation" and his concealment forced costly discovery. +- **In re Marriage of Crosetto, 82 Wn. App. 545, 918 P.2d 954 (1996)** (Court of Appeals, Division Two). **Holding:** A pattern of obstruction (false abuse allegations, thwarting visitation) was intransigence; on remand the trial court was directed to **segregate** fees caused by intransigence from the fees the parties otherwise bear themselves. + +### Fees on appeal + +Appellate courts examine the **arguable merit** of the issues on appeal and the **financial resources** of the parties, under RCW 26.09.140 and RAP 18.1. In *Sheffer*, the wife won appellate fees based on income disparity; in *Mansour*, she earned them after showing merit, complying with RAP 18.1(b), and filing an affidavit of financial need. + +## Practical takeaways + +- Maintenance is discretionary, fact-driven, and never automatic — there is no formula. +- Long marriages, homemaker sacrifices, disability, and earning-power gaps favor longer or larger awards; *Washburn*, *Sheffer*, and *Bulicek* are the anchors. +- Courts may not consider fault in awarding maintenance (*Muhammad*), but may consider a spouse's intransigence in awarding fees (*Greenlee*, *Mattson*, *Crosetto*). +- Modification requires a genuine, post-decree change in circumstances; voluntary income reduction does not qualify (*Lambert*), but serious illness can (*Spreen*, *Drlik*). +- Fee awards balance need against ability to pay (*Knight*, *Mansour*); no lodestar formula is required (*Van Camp*). +- Maintenance ends automatically on death or the recipient's remarriage unless the decree or agreement says otherwise (RCW 26.09.170(2)); reconciliation does not void a separation decree's maintenance terms (*Moody*). diff --git a/divorce-dissolution.md b/divorce-dissolution.md new file mode 100644 index 0000000..39884c6 --- /dev/null +++ b/divorce-dissolution.md @@ -0,0 +1,144 @@ +# Divorce (Dissolution) in Washington State + +> For educational purposes only — not legal advice. + +## What this book covers + +This book explains how a marriage ends in Washington State: the legal paths available (divorce, legal separation, annulment), who can file, how the process works, and what a final court order can do. The rules are set out in Chapter 26.09 of the Revised Code of Washington (RCW). The same chapter applies to registered domestic partnerships — Washington law handles dissolution of a domestic partnership through the same court process, with some different form names (WashingtonLawHelp.org, *Divorce basics*). + +Washington calls a divorce a **dissolution of marriage**. You get one by asking a superior court for a court order that ends your marriage. You cannot be divorced by private agreement — only a judge's signed final order ends a marriage in Washington (WashingtonLawHelp.org, *Divorce guide*). + +## Washington is a no-fault state + +You do not have to prove your spouse did something wrong. To get a divorce, the person filing (the petitioner) states in the petition that the marriage is **irretrievably broken** (RCW 26.09.030). This is a legal way of saying at least one spouse believes the marriage cannot be saved. + +Key consequences of no-fault divorce: + +- If your spouse does not want a divorce, you can still get one if the court finds the marriage irretrievably broken (RCW 26.09.030(c)). +- Fault — such as adultery, abandonment, or cruelty — is not a requirement for divorce, and it is generally not a factor in dividing property (RCW 26.09.080) or awarding spousal maintenance (RCW 26.09.090). Washington courts award both "without regard to misconduct." +- Washington does not recognize common-law marriage created in Washington, though a common-law marriage validly created in another state or country counts here (WashingtonLawHelp.org, *Divorce basics*). + +## Who can file: residency and military service + +Washington has no minimum length of residence. The court can hear a divorce petition when any one of these is true (RCW 26.09.030): + +1. The petitioner or the respondent is a resident of Washington State; +2. The petitioner or the respondent is a member of the armed forces stationed in Washington; or +3. The petitioner or the respondent is married to a person who is a resident of Washington or is a service member stationed in Washington. + +In practice, WashingtonLawHelp.org (*Divorce basics*) describes it this way: you can file when you or your spouse lives in Washington and plans to stay, or when you or your spouse is in the military and will be stationed here for at least 90 days after the case is filed. + +Divorce cases are filed in **superior court** — there is a superior court in every county. File in the superior court of the county where you or your spouse lives; contact that court's clerk or family law facilitator to confirm local requirements (WashingtonLawHelp.org, *Divorce guide*; Washington Courts eService Center FAQ, "Filing for divorce in Washington State"). + +## Three ways to end a marriage + +Washington law provides three kinds of family-law cases under Chapter 26.09 RCW: + +### Dissolution (divorce) + +This ends the marriage entirely. The decree is final when entered, subject to the right of appeal, and either party may remarry after the decree (RCW 26.09.150(1)). + +### Legal separation + +A decree of legal separation gives the court authority over the same issues as a divorce — parenting plan, child support, maintenance, and division of property and debts — but the marriage continues. You remain legally married. People often choose legal separation for religious reasons, or to preserve Social Security benefits that depend on being married (WashingtonLawHelp.org, *Legal separation basics*). + +Differences from divorce that matter in practice: + +- There is **no 90-day waiting period** for a legal separation (WashingtonLawHelp.org, *Legal separation basics*). +- You cannot remarry while separated — the decree can later be **converted to a divorce**. Either party may ask for conversion, but not earlier than six months after the separation decree is entered (RCW 26.09.150(2)(a)). +- A petitioner may ask for legal separation instead of dissolution in the original petition (RCW 26.09.030(d)). + +### Declaration of invalidity (annulment) + +An annulment is a court ruling that the marriage should be treated as though it never validly existed. A petition may be filed while both parties are living, by either or both parties (or a guardian for an incompetent spouse), when the marriage should not have been contracted for reasons including (RCW 26.09.040): + +- Age of one or both parties (too young to marry); +- Lack of required parental or court approval; +- A prior, still-existing marriage or domestic partnership of one party; +- Consanguinity (the spouses are close blood relatives); +- A party lacked capacity to consent, because of mental incapacity or the influence of alcohol or other incapacitating substances; +- A party was induced to marry by force or duress, or by fraud involving the essentials of marriage. + +A marriage entered in another place that was void or voidable under that place's law may also be declared invalid (RCW 26.09.040(4)(c)). Even in an annulment, the court has authority to award maintenance, order a parenting plan for minor children, and divide property (RCW 26.09.040(3)). Children born or conceived during the marriage stay legitimate even if the marriage is declared invalid (RCW 26.09.040(5)). + +## The 90-day waiting period + +Washington imposes a mandatory waiting period: the judge may not enter a decree of dissolution until **90 days have passed since the petition was filed and since the summons was served** (or first published) on the other spouse (RCW 26.09.030). This is the fastest any divorce can be finalized, even when both spouses agree on everything (WashingtonLawHelp.org, *Divorce guide*). Contested divorces take longer — often many months — because the judge must decide disputed issues, sometimes after a trial. + +## The court process, step by step + +WashingtonLawHelp.org's *Divorce guide* (reviewed May 2026) lays out the basic path: + +1. **Prepare and file forms.** The core forms are the *Summons* (FL Divorce 200), the *Petition for Divorce (Dissolution)* (FL Divorce 201), and the *Confidential Information* form (FL All Family 001), which is for the court only and is never served on the other spouse (Washington Courts, "Court Forms: Divorce (Dissolution)"; WashingtonLawHelp.org, *Divorce guide*). Free guided form tools are available through Washington Forms Online. +2. **Pay the filing fee or get it waived.** The filing fee is currently **$364** (WashingtonLawHelp.org, *Divorce guide*). You can ask the judge to waive filing fees and surcharges under court rule **GR 34** if you receive TANF, SSI, HEN, food assistance, or federal poverty-related veterans' benefits; or your income is at or below 125% of the federal poverty guidelines; or basic living expenses keep you from paying (WashingtonLawHelp.org, *Ask the court for a fee waiver*; courts.wa.gov, GR 34). +3. **Serve your spouse.** Generally someone other than you must hand-deliver the papers. Personal service is not needed if your spouse signs a *Service Accepted* form or an *Agreement to Join Petition (Joinder)* (WashingtonLawHelp.org, *Divorce guide*; courts.wa.gov forms FL All Family 119, 117). +4. **Wait for a response.** A spouse served in Washington has 20 days to respond; 60 days if served outside Washington; 90 days if served by mail or publication; and (from September 1, 2025) 60 days for a person who receives the papers while in jail or prison (WashingtonLawHelp.org, *Divorce guide*). If there is no response, you can ask for an order of **default**, which lets the case proceed without the spouse's participation (WashingtonLawHelp.org, *Divorce guide*). +5. **Temporary orders, if needed** (see next section). +6. **Finalize.** If you agree on everything, you submit final orders (including *Findings and Conclusions About a Marriage*, FL Divorce 231, and the *Final Divorce Order*, FL Divorce 241) for the judge to sign. If you disagree, the judge decides after a trial. You are legally divorced when the judge signs the Final Divorce Order and it is filed; the court clerk then forwards a *Certificate of Dissolution* (DOH 422-027) to the State Registrar of Vital Statistics (WashingtonLawHelp.org, *Divorce guide*; courts.wa.gov forms page). + +## Temporary orders while the case is pending + +Either spouse can ask the judge for short-term orders that apply until the divorce is final (RCW 26.09.060). A motion for temporary maintenance or temporary child support must include an affidavit stating the facts and the amounts requested (RCW 26.09.060(1)). The court can also issue temporary restraining orders or preliminary injunctions that: + +- Stop either party from transferring, hiding, or disposing of property outside the ordinary course of business (RCW 26.09.060(2)(a)); +- Prohibit molesting or disturbing the other party or any child (RCW 26.09.060(2)(b)); +- Keep one party away from the home, workplace, or school of the other party or the children (RCW 26.09.060(2)(c), (d)); +- Stop a party from removing a child from the state (RCW 26.09.060(2)(e)). + +For safety emergencies, a party may request a domestic violence or antiharassment **protection order** under Chapter 7.105 RCW. Temporary (ex parte) protection orders issued this way last up to 14 days, extendable to 24 days to consolidate hearings (RCW 26.09.060(3)). The court must consider firearm restrictions under RCW 9.41.800 and can order surrender of firearms and dangerous weapons (RCW 26.09.060(4)). Forms include the *Motion for Temporary Family Law Order and Restraining Order* (FL Divorce 223) and the *Motion for Immediate Restraining Order (Ex Parte)* (FL Divorce 221) (courts.wa.gov forms page). Temporary orders end when the final decree is entered (RCW 26.09.060(10)(c)). + +## What the final decree can do + +When entering a decree of dissolution, legal separation, or invalidity, the court must address, as applicable (RCW 26.09.050(1)): + +- A **parenting plan** for any minor children (see next section); +- **Child support**; +- **Maintenance (spousal support)** for either spouse — see the companion book *Spousal Maintenance in Washington State*; +- **Division of property and debts**; +- Allocation of the children as federal tax exemptions; +- Any needed continuing **restraining orders** or protection orders under Chapter 7.105 RCW; and +- A **name change**, if a party requests restoration of a former name or a new name (see also RCW 26.09.150(3)). + +## Dividing property and debts + +Washington is a **community property** state. In general, property and debts acquired during the marriage are community property; property owned before the marriage, or received by gift or inheritance, is typically separate property. The court must divide the property and liabilities of the parties — both community and separate — in a way that is "just and equitable," considering (RCW 26.09.080): + +1. The nature and extent of the community property; +2. The nature and extent of the separate property; +3. The length of the marriage; and +4. The economic circumstances of each spouse at the time of division, including the desirability of letting the parent with whom the children mostly live keep the family home for a reasonable time. + +Two practical cautions: + +- **Retirement benefits count.** Pensions, 401(k)s, IRAs, and similar accounts earned during the marriage are generally community property subject to division, even if one spouse never worked outside the home. Dividing many employer plans requires a special court order called a QDRO (Qualified Domestic Relations Order). Acting quickly after the decree matters — a delayed division can result in the account owner keeping everything (Legal Voice, *Divorce and Future Retirement Benefits*, updated June 2025). +- **Property division is final.** Unlike maintenance and child support, a property division generally cannot be modified later; a court may revisit it only under conditions that justify reopening a judgment (RCW 26.09.170(1)). + +## Parenting plans and child support + +In any case involving minor children, the best interests of the child is the standard the court applies (RCW 26.09.002). Every final decree with children includes a **permanent parenting plan** that sets residential time and decision-making authority (RCW 26.09.184; the criteria the court must use are in RCW 26.09.187 and RCW 26.09.191). Child support is set under Chapter 26.19 RCW using the Washington State Child Support Schedule, based on both parents' incomes (WashingtonLawHelp.org, *Divorce guide*). + +## Settling your case: separation contracts + +You and your spouse may resolve things by written agreement. A **separation contract** can cover maintenance, division of property, parenting, and child support (RCW 26.09.070(1)). When a divorce is filed, the contract is binding on the court unless the court finds it was unfair at the time it was made (RCW 26.09.070(3)). Notably, a separation contract may state that a maintenance provision cannot be modified later; without that language, maintenance terms can be modified like any decree provision (RCW 26.09.070(7)). Agreements on parenting plans and child support are always reviewable by the court for the child's best interests and compliance with the child support schedule (RCW 26.09.070(3)). + +## Attorney fees and help + +The court may order one party to pay a reasonable amount toward the other party's attorney fees and costs, based on the parties' financial resources (RCW 26.09.140). There is no right to a court-appointed lawyer in a divorce (WashingtonLawHelp.org, *Enforce your divorce decree*). + +If your spouse ignores the final order, remedies include motions for contempt — for example, a parent who refuses to comply with a parenting plan can face contempt, attorney-fee awards, and civil penalties (RCW 26.09.160). Money judgments from a divorce can generally be enforced for 10 years and renewed (WashingtonLawHelp.org, *Enforce your divorce decree*). + +Sources of help and forms: + +- **WashingtonLawHelp.org** — free plain-language guides and Washington Forms Online (washingtonlawhelp.org, maintained by Northwest Justice Project). +- **Washington State Courts** — statewide court forms and the Court Directory: courts.wa.gov. +- **Legal Voice** — legal publications for Washington residents: legalvoice.org. +- **CLEAR** — statewide legal aid referral line: 1-888-201-1014 (courts.wa.gov forms page). +- **Family law facilitators** — some counties provide facilitators who help with paperwork (no legal advice). +- **Military spouses** — federal law gives active-duty service members extra protections, including postponement of hearings; check military status via the Defense Manpower Data Center (WashingtonLawHelp.org, *Divorce guide*). + +## Sources + +- RCW 26.09.002, 26.09.030, 26.09.040, 26.09.050, 26.09.060, 26.09.070, 26.09.080, 26.09.090, 26.09.140, 26.09.150, 26.09.160, 26.09.170, 26.09.184 — app.leg.wa.gov (Title 26, Chapter 26.09 RCW) +- WashingtonLawHelp.org (Northwest Justice Project): *Divorce guide* (reviewed 05/07/2026); *Divorce basics* (reviewed 09/03/2026); *Legal separation basics*; *Ask the court for a fee waiver*; *Enforce your divorce decree: Money and property issues* (reviewed 03/19/2026) — washingtonlawhelp.org +- Washington State Courts: *Court Forms: Divorce (Dissolution)* — courts.wa.gov/forms/?fa=forms.contribute&formID=13; eService Center FAQ *Filing for divorce in Washington State* — info.courts.wa.gov; General Rule 34 (fee waivers) — courts.wa.gov +- Legal Voice: *Divorce and Future Retirement Benefits* (updated June 2025) — legalvoice.org diff --git a/guardianship.md b/guardianship.md new file mode 100644 index 0000000..694feaa --- /dev/null +++ b/guardianship.md @@ -0,0 +1,97 @@ +For educational purposes only — not legal advice. + +# Guardianship in Washington State: A Plain-English Guide to Chapter 11.130 RCW + +## What This Book Covers + +This book explains Washington's guardianship law: the "uniform guardianship, conservatorship, and other protective arrangements act," chapter 11.130 RCW (RCW 11.130.005). It covers minor guardianship in depth, its comparison with parenting plans, and adult-guardianship basics. Minor-guardianship provisions took effect January 1, 2021 (RCW 11.130.915(2)); adult guardianships and conservatorships took effect January 1, 2022 (RCW 11.130.915), applying to proceedings begun after that date and to existing guardianships (RCW 11.130.910). + +## Part 1 — Minor Guardianship + +### What Minor Guardianship Is + +A "guardian" is a person appointed by a court to make decisions about another person's personal affairs; a "minor" is an unemancipated person under eighteen (RCW 11.130.010(11), (20)). Guardianship exists only by court appointment — never by private agreement alone (RCW 11.130.185(1)). + +### The 2020–2021 Change: Nonparental Custody Became Minor Guardianship + +Before January 1, 2021, a nonparent seeking custody of someone else's child filed a "nonparental custody" case under chapter 26.10 RCW, repealed effective January 1, 2021 (2020 c 312 § 905, per the official disposition history of chapter 26.10 RCW). Today a nonparent obtains custody and decision-making authority through a minor guardianship; pre-repeal chapter 26.10 RCW orders remain valid, but modifications must follow chapter 11.130 RCW (RCW 11.130.245(1), (2)). + +### Grounds: When a Court May Appoint a Guardian for a Minor + +A court may appoint a guardian for a minor who does not already have one only if the appointment is in the minor's best interest and one of three grounds exists (RCW 11.130.185(2)): + +- Each parent, after being fully informed of the nature and consequences of guardianship, consents (RCW 11.130.185(2)(a)). +- All parental rights have been terminated (RCW 11.130.185(2)(b)). +- There is clear and convincing evidence that no parent is willing or able to exercise "parenting functions" as defined in RCW 26.09.004 (RCW 11.130.185(2)(c)) — maintaining a loving, stable relationship; meeting the child's daily needs and education; and exercising appropriate judgment (RCW 26.09.004(2)). + +### Who May Petition and Where + +"A person interested in the welfare of a minor, including the minor, may petition for appointment of a guardian for the minor" (RCW 11.130.190(1)); the petitioner need not be the person seeking to become guardian. The petition must state the petitioner's name, address, and relationship to the minor and, so far as known, the names and addresses of the minor, the parents, and recent caregivers; the legal basis, with the factual reasons in a separate declaration; the proposed guardian and why; the minor's property; interpreter needs; and any other pending proceeding (RCW 11.130.190(2)). Venue is the county where the minor resides or is present, or where another custody or parental-rights proceeding is pending (RCW 11.130.030(1)). + +### Who May Serve as Guardian + +Any suitable person over age 21 — or a parent under 21 — may be appointed if not disqualified (RCW 11.130.090(1)). Disqualifiers include being under 18 (with exceptions); certain criminal convictions, though a relative may still qualify after court review; nonresidents without a resident agent; corporations not authorized to act as fiduciary; or persons found unsuitable (RCW 11.130.090(1)(a)–(e)). Lay guardians must complete the free AOC training video or webcast (deferrable up to 90 days in expedited cases) unless waived (RCW 11.130.090(2)). Before a final order, the court must obtain child-welfare records and state and national criminal-history checks on each proposed guardian and adult household member (RCW 11.130.210). + +### Notice, Hearing, and the Child's Voice + +The petitioner must personally serve the petition and notice on the minor (if 12 or older), each parent (or the nearest adult kin), any existing guardian or nonparental custodian under former chapter 26.10 RCW, and anyone else the court directs (RCW 11.130.195(1)(a)); mail notice goes to a broader list including grandparents, adult siblings, prior caregivers, and nominees (RCW 11.130.195(1)(b)). The court may not grant the guardianship if the minor (12+) or the parents were not served, unless clear and convincing evidence shows a parent cannot be located with due diligence or waived notice in a record (RCW 11.130.195(3)). When a parent cannot be served, or an unrepresented minor 12 or older is involved, the court appoints a court visitor to investigate and report (RCW 11.130.195(4)). + +A minor 12 or older may request an attorney, whom the court may also appoint on a guardian ad litem's recommendation or its own motion; counsel advocates the minor's wishes, or legal rights if not reasonably ascertainable (RCW 11.130.200(1)–(2)). An indigent parent who objects is entitled to appointed counsel (RCW 11.130.200(5)–(6)). The minor may attend and participate unless the court finds participation meaningless or harmful (RCW 11.130.205(1)). + +### Whom the Court Appoints First + +The court must appoint a person a parent nominated in a probated will or other sworn record (which may include a power of attorney) unless contrary to the minor's best interest; if parents nominate different people, the court chooses by best interest; otherwise it appoints the minor's own nominee, if 12 or older, unless contrary to the minor's best interest (RCW 11.130.215(2)). The court may create a "limited guardianship" granting fewer than all available powers (RCW 11.130.215(3)). The order must preserve the parent-child relationship through visitation unless restricted under RCW 26.09.191 or 26.09.192, and must state the rights each parent retains (RCW 11.130.215(4)); parents are entitled to notice of any delegation of custody or of modification, limitation, or removal of the guardian (RCW 11.130.215(5)). + +### Emergency and Standby Guardians + +The court may appoint an emergency guardian if that is likely to prevent substantial harm to the minor's health, safety, or welfare and no other person has the authority, ability, and willingness to act (RCW 11.130.225(1)). It lasts at most 60 days, extendable once for 60 more (RCW 11.130.225(2)). Without notice, appointment requires a finding that the minor would be substantially harmed before a noticed hearing; notice then follows within 48 hours and a hearing within 5 days (RCW 11.130.225(4)). An emergency appointment is not a finding that grounds for a full guardianship exist (RCW 11.130.225(5)). Separately, a parent may nominate a "standby guardian," appointed on a finding that within two years no parent likely will be able or willing to perform parenting functions (RCW 11.130.220(2)–(3)), who acts only when no parent is willing or able (RCW 11.130.220(1)). + +### Guardian Duties for a Minor + +A guardian for a minor is a fiduciary and, except as limited by the court, "has the duties and responsibilities of a parent regarding the minor's support, care, education, health, safety, and welfare" (RCW 11.130.230(1)). The guardian must act in the minor's best interest with reasonable care, diligence, and prudence; stay personally acquainted with the minor; spend the minor's funds on current needs and conserve the rest; report and account if the court orders; report any change of dwelling; and consider the minor's preferences (RCW 11.130.230(1)–(2)). Unlike adult guardianships, minor guardians have no automatic periodic reporting — a report is required only if ordered (RCW 11.130.230(2)(e)). + +### Guardian Powers for a Minor + +Except as limited by court order, a guardian has the powers a parent would have regarding the minor's support, care, education, health, safety, and welfare (RCW 11.130.235(1)): applying for benefits payable for the minor's support; taking custody and establishing the minor's dwelling in-state (out-of-state moves require the relocation process of RCW 26.09.405 through 26.09.560 plus court authorization); compelling child support; consenting to health care; and delegating age-appropriate responsibility (RCW 11.130.235(2)). Only if the minor has no parent may the court authorize the guardian to consent to adoption (RCW 11.130.235(3)). The court may order parents to pay child support under chapter 26.19 RCW (RCW 11.130.255) and maintain employer-based health insurance (RCW 11.130.260). A parent needing less than guardianship may delegate care, custody, or property powers by power of attorney for up to 24 months — except consent to marriage or adoption (RCW 11.130.145). + +### Court Oversight and Ending a Minor Guardianship + +A minor guardianship terminates on the minor's death, adoption, emancipation, or attainment of majority, or when the court finds the basis for appointment no longer exists — unless termination would harm the minor and the minor's interest in continuing outweighs the parent's interest in restoring decision-making rights (RCW 11.130.240(1)). The minor, a parent, or any interested person may petition to terminate or modify the guardianship or remove the guardian (RCW 11.130.240(2)); the court may order transitional arrangements (RCW 11.130.240(6)). + +Anyone subject to a guardianship, or any interested person, who reasonably believes a guardian is breaching fiduciary duty may file a grievance; the court must review it and may investigate, order reports, appoint a court visitor, or hold a hearing (RCW 11.130.140). Every petition must state whether the child is or may be an "Indian child" (RCW 13.38.040); if so, the federal Indian Child Welfare Act and chapter 13.38 RCW apply, and the order must include required findings (RCW 11.130.250). + +## Part 2 — Minor Guardianship vs. Parenting Plans + +### Parenting Plans Are for Parents + +A "parenting plan" allocates a child's care and decision-making between the child's own parents in a dissolution, legal separation, or parentage case, covering physical care, emotional stability, and each parent's authority and responsibilities (RCW 26.09.184(1)–(2)). A minor guardianship instead places a nonparent in a parent-like role without terminating parental rights — the order must preserve visitation unless restricted under RCW 26.09.191 or 26.09.192 (RCW 11.130.215(4)) — and ends at age 18 (RCW 11.130.215(7); RCW 11.130.240(1)(a)). + +### De Facto Parentage Is a Different Path + +A person who is not a legal parent but claims to have functioned as one may instead seek adjudication as a "de facto parent" under the Uniform Parentage Act, proving by a preponderance: residence with the child as a regular household member for a significant period; consistent caretaking; full parental responsibilities without expectation of pay; holding the child out as their own; and a bonded, parental relationship (RCW 26.26A.440(4)). De facto parentage makes the person a legal parent; guardianship makes the person a guardian while the parents stay parents. + +## Part 3 — Adult Guardianship: The Basics + +The same chapter governs adult guardianships, which replaced former chapter 11.88 RCW (repealed by 2020 c 312 § 904, effective January 1, 2022, per its official disposition history). + +### Grounds for an Adult Guardianship + +A court may appoint a guardian for an adult only on clear and convincing evidence that the adult cannot meet essential requirements for physical health, safety, or self-care because the adult cannot receive and evaluate information or make or communicate decisions, even with supports or supported decision making; that appointment is necessary to prevent significant risk of harm; and that the adult's needs cannot be met by a protective arrangement or another less restrictive alternative (RCW 11.130.265(1)). A full guardianship is barred if a limited guardianship or less restrictive alternative would work (RCW 11.130.265(2)). Age, eccentricity, poverty, or a diagnosis alone is not enough (RCW 11.130.265(3)). + +### Who May Be Appointed + +Priority: a guardian in another jurisdiction; the adult's nominee, including in a power of attorney; the adult's health care agent; a spouse or domestic partner; a relative or other person of special care and concern; then a certified professional guardian (RCW 11.130.305(1)). The order must state whether the adult retains the rights to vote and marry — retained unless the order contains removal findings (RCW 11.130.310(1)–(2)). + +### Duties, Powers, and Limits + +An adult guardian is a fiduciary owing the highest duty of good faith, must promote the adult's self-determination, and may not substitute the guardian's own moral, religious, or philosophical values (RCW 11.130.325(1)–(2)). The decision-making standard is "substituted judgment": make the decision the adult would make if able, unless that would unreasonably harm the adult, in which case act in the adult's best interest (RCW 11.130.325(4)–(5)). Powers include establishing the adult's dwelling, consenting to health care, and receiving funds, benefits, and health information (RCW 11.130.330(1)). The guardian may not revoke or amend the adult's powers of attorney, and agents' decisions under those powers generally take precedence (RCW 11.130.335(1)); involuntary commitment must follow chapters 10.77, 71.05, or 72.23 RCW (RCW 11.130.335(2)). Adults under guardianship retain the right to associate with people of their choosing unless the court authorizes a restriction (RCW 11.130.335(5)). + +### Court Oversight + +An adult guardian must file a care plan within 90 days of appointment, which the court reviews and approves (RCW 11.130.340(1), (4)). The guardian then files periodic reports — annual, biennial, or triennial — on the adult's condition, living arrangements, services, visits, and funds; the court reviews each for compliance and continued need (RCW 11.130.345(1)–(2), (5), (9)). A guardian may be removed for failure to perform duties or other good cause (RCW 11.130.350(1)); the adult, the guardian, or an interested person may petition for termination or modification (RCW 11.130.355(1)). The grievance process of RCW 11.130.140 applies to adult guardianships too, and findings of a professional guardian's fiduciary breach go to the Certified Professional Guardianship Board (RCW 11.130.140(5); RCW 11.130.670). + +## Where to Learn More + +- Statute text: chapter 11.130 RCW — https://app.leg.wa.gov/rcw/default.aspx?cite=11.130 +- Washington Law Help (Northwest Justice Project): "Minor guardianship guide," "Children's rights in minor guardianship" — washingtonlawhelp.org +- Washington State Courts Guardian Portal — courts.wa.gov/guardianportal — forms, the free lay-guardian training, and the Office of Guardianship and Elder Services. diff --git a/mediation-adr.md b/mediation-adr.md new file mode 100644 index 0000000..6b10340 --- /dev/null +++ b/mediation-adr.md @@ -0,0 +1,109 @@ +# Washington Family Law: Mediation and Alternative Dispute Resolution (ADR) + +> For educational purposes only — not legal advice. + +This book explains the out-of-court ways Washington family law disputes get resolved: mediation, settlement conferences, parenting-plan dispute resolution, arbitration, collaborative law, and guardians ad litem. It is written for Washington State residents in plain English. Sources: RCW statutes at app.leg.wa.gov, WashingtonLawHelp.org, courts.wa.gov, King County Superior Court Local Family Law Rules, and WSBA materials. All citations were verified September 2026. + +## What ADR means in a Washington family law case + +"Alternative dispute resolution" (ADR) is any process that resolves your case without a judge deciding it at trial. In Washington family law, ADR is not just optional — courts are **directed to steer parties toward settlement**, and some form of ADR is often **required before trial**. The main processes are mediation, settlement conferences, arbitration, and collaborative law *(RCW 26.09.015; King County LFLR 16; RCW 26.09.184(4))*. + +## Court-ordered mediation under RCW 26.09.015 + +In any divorce or legal separation proceeding, "the matter **may be set for mediation** of the contested issues before, or concurrent with, the setting of the matter for hearing" *(RCW 26.09.015(1))*. Key points from the statute: + +- **Purpose:** reduce acrimony between the parties and "develop an agreement assuring the child's close and continuing contact with both parents." The mediator must use best efforts to settle the dispute *(RCW 26.09.015(1))*. +- **Who provides it:** each superior court may make a mediator available, using the most cost-effective mediation services readily available *(RCW 26.09.015(2)(a))*. +- **Reduced or waived fees:** counties **may** — and, when state funding is provided, **shall** — offer pre-decree and post-decree mediation at reduced or waived fees to parties within one year of the filing of the dissolution petition *(RCW 26.09.015(2)(b))*. +- **The child's interests:** the mediator must assess the needs and interests of the children involved and may interview a child when appropriate *(RCW 26.09.015(4))*. +- **Result:** any agreement reached in mediation is reported to the court and to counsel *(RCW 26.09.015(5))*. + +Practical takeaway: mediation is voluntary in the sense that you negotiate freely, but the court can set your case for it, and participating in good faith is expected. If you reach agreement, the mediator reports it and the court can enter it as your final orders *(RCW 26.09.015(5); WashingtonLawHelp, "Divorce guide")*. + +## Mediation when domestic violence or child abuse is involved + +Mediation is **"generally inappropriate"** in cases involving domestic violence or child abuse. The law directs that, where appropriate, parties be given access to trained domestic violence advocates, and it allows mediation in such cases **only** when a victim requests it and the court makes a finding that mediation is appropriate under the circumstances, with the victim permitted to have a supporting person present *(RCW 26.09.016)*. In practice, local court rules also excuse parties from mandatory ADR in cases with documented domestic violence (see, e.g., King County LFLR 16 below). If you are a victim of domestic violence, tell the court and ask about these exceptions before agreeing to mediate *(RCW 26.09.016; King County LFLR 16(a))*. + +## Confidentiality of mediation + +Mediation in family law is governed by Washington's mediation confidentiality statute, **chapter 7.07 RCW** *(RCW 26.09.015(3)(a))*. Generally, mediation communications are privileged: what you say in mediation cannot be used against you in court, and a mediator can be compelled to testify only by court order for good cause *(RCW 26.09.015(3)(b); RCW 7.07.010)*. Exceptions: in **post-decree mediations mandated by a parenting plan**, mediation communications can be admitted in later proceedings for the limited purpose of proving abuse, neglect, abandonment, exploitation, or unlawful harassment of a child or family member *(RCW 26.09.015(3)(a)(i))*. + +## Settlement conferences + +A settlement conference is a meeting — usually with a judge, court commissioner, or volunteer attorney — where the parties try to settle the case on the eve of trial. It is more evaluative than mediation: the neutral may tell you how the case is likely to come out. + +- WashingtonLawHelp notes that some courts **offer or require** settlement conferences before trial *(WashingtonLawHelp, "Divorce guide")*. +- **King County requires ADR:** "Except in cases involving domestic violence, or where waived by a court order, the parties in every case **shall participate in a settlement conference, mediation or other alternative dispute resolution process** conducted by a neutral third person no later than thirty (30) days before trial" *(King County LFLR 16(a))*. All parties and attorneys must personally attend and participate, come prepared with proposed final orders, a financial declaration, and (if parenting is at issue) a proposed parenting plan, and each party has a duty to act in good faith — failure can result in sanctions *(King County LFLR 16(b)–(d))*. +- King County also runs a **Volunteer Settlement Conference Program** that pairs low-income families with volunteer attorneys to resolve cases without trial *(King County Superior Court)*. + +Because these rules are **local**, check your own county's "Local Family Law Rules" — most counties publish them on the county superior court website. + +## Parenting-plan dispute resolution (RCW 26.09.184) + +Every **permanent parenting plan** must include a section titled "Dispute Resolution" providing **"a process for resolving disputes, other than court action"** — such as counseling, mediation, or arbitration by a specified individual or agency — unless precluded or limited by the statutes protecting parents in domestic violence or abuse situations *(RCW 26.09.184(4), referencing RCW 26.09.187 and 26.09.191)*. The statute requires that: + +- Preference be given to carrying out the parenting plan; +- Parents use the designated process for disputes about implementing the plan (except financial support disputes) unless there is an emergency; +- A written record be made of agreements and arbitration awards; +- A parent who **uses or frustrates the dispute resolution process without good reason** pays the other parent's attorney fees and financial sanctions; and +- The parties have a **right of review** from the dispute resolution process to the superior court *(RCW 26.09.184(4)(a)–(f))*. + +This is why many parenting plans name a specific mediator or a "mediation-arbitration" provider for future disputes *(RCW 26.09.015(3)(a)(ii); RCW 26.09.184(4))*. + +## Arbitration (Chapter 26.14 RCW — Uniform Family Law Arbitration Act) + +Since 2023, Washington has a dedicated family law arbitration statute: the **Uniform Family Law Arbitration Act**, chapter 26.14 RCW *(RCW 26.14.005; 2023 c 61)*. Arbitration is like a private trial: the parties agree in writing to let a neutral arbitrator hear evidence and issue a **binding award**, which the court can confirm and enter as a judgment *(RCW 26.14.150, .200)*. + +Important limits: + +- An arbitrator **cannot** grant a divorce, legal separation, or annulment, terminate parental rights, grant an adoption or guardianship, or decide dependency status — only a judge can sign the final decree *(RCW 26.14.020(2))*. +- The act does **not** apply to protection orders (chapter 7.105 RCW), jurisdictional disputes, venue, or the court's authority to permanently modify a parenting plan based on a substantial change of circumstances *(RCW 26.14.020(3))*. +- Arbitrators must follow disclosure and qualification rules, and awards can be corrected, vacated, or appealed to the court *(RCW 26.14.070–.230)*. + +Arbitration is chosen **by agreement of the parties**, typically written into a settlement agreement or parenting plan. It is usually faster and more private than court, but you give up a judge's decision and you generally pay the arbitrator's fees *(RCW 26.14.010, .040)*. + +## Collaborative law (Chapter 7.77 RCW) + +Collaborative law is a structured, voluntary process in which each spouse hires a lawyer, everyone signs a **collaborative law participation agreement**, and the group commits to negotiate a settlement **without going to court** *(RCW 7.77.010, .030)*. Key features under Washington's Uniform Collaborative Law Act: + +- The agreement must be in writing, describe the matter, and identify each party's collaborative lawyer *(RCW 7.77.030)*. +- **Voluntary:** a tribunal cannot order a party into collaborative law over their objection, and either party may end the process at any time, with or without cause *(RCW 7.77.040(2), (6))*. +- **The disqualification rule:** if the process fails, the collaborative lawyers (and their law firms) are **disqualified** from representing the parties in court — which gives everyone a strong incentive to settle. The exception is asking a court to approve an agreement or to obtain an emergency order *(RCW 7.77.080)*. +- **Full, informal disclosure:** parties must exchange relevant information candidly without formal discovery *(RCW 7.77.100)*. +- **Emergency orders still available:** a court can issue emergency orders to protect health and safety during the process *(RCW 7.77.060)*. +- If a court case is already pending, filing the participation agreement operates as an application to **stay (pause) the proceeding** *(RCW 7.77.050)*. + +Collaborative law often includes neutral experts — financial specialists, child specialists, or coaches — and ends with the court approving the parties' signed agreement *(RCW 7.77.070)*. + +## Guardians ad litem (GALs) + +A Guardian ad Litem (GAL) is a neutral person appointed by the court to represent the **best interests of a child** in a family law case *(RCW 26.12.175(1)(a))*. + +- The GAL's role is to **investigate and report** factual information on the issues the court orders, and to make recommendations the court may weigh alongside the parties' positions. If a child expresses a preference about the parenting plan, the GAL must report it, along with whether the preference is voluntary and how well the child understands it *(RCW 26.12.175(1)(b))*. +- The GAL must file the report **at least 60 days before trial**, and the parties may file written responses *(RCW 26.12.175(1)(b)–(c))*. +- **Cost:** the court orders costs and fees to be paid by either or both parents according to their ability to pay; if both parents are indigent, the county bears the cost *(RCW 26.12.175(1)(d))*. Note that GAL fees are generally **not** covered by a GR 34 fee waiver *(WashingtonLawHelp, "Ask the court for a fee waiver")*. +- Separately, the court may order a **parenting evaluation** — an investigation and report concerning parenting arrangements — with or without a GAL *(RCW 26.09.220)*. + +A GAL is not a lawyer for your child and is not your advocate; the GAL reports to the court about what is best for the child *(RCW 26.12.175(1)(b))*. + +## Choosing the right process + +| Situation | Usually best fit | +|---|---| +| You and your spouse can talk, mostly agree, want to save time/money | Mediation or settlement conference *(RCW 26.09.015; LFLR 16)* | +| You want to keep the case out of court entirely and have lawyers | Collaborative law *(RCW 7.77)* | +| You want a faster, private, binding decision and can agree on an arbitrator | Arbitration *(RCW 26.14)* | +| Post-divorce disputes about the parenting plan | The dispute resolution process named in your plan *(RCW 26.09.184(4))* | +| Domestic violence or child abuse | NO mediation unless you request it and the court approves; seek an advocate *(RCW 26.09.016)* | +| The court needs independent information about your child | Guardian ad Litem or parenting evaluation *(RCW 26.12.175; RCW 26.09.220)* | + +## Sources + +- RCW 26.09.015 (mediation proceedings), .016 (mediation and domestic violence), .184(4) (parenting plan dispute resolution), .187, .191, .220 — app.leg.wa.gov +- RCW 26.12.175 (guardians ad litem) — app.leg.wa.gov +- Chapter 26.14 RCW (Uniform Family Law Arbitration Act, 2023 c 61) — app.leg.wa.gov +- Chapter 7.77 RCW (Uniform Collaborative Law Act) — app.leg.wa.gov +- Chapter 7.07 RCW (mediation confidentiality) — app.leg.wa.gov +- King County Superior Court Local Family Law Rules, LFLR 16 (ADR) — kingcounty.gov +- WashingtonLawHelp.org — "Divorce guide" and "Ask the court for a fee waiver" (reviewed 05/07/2026) +- King County Superior Court — Settlement Conference Program diff --git a/modification-enforcement.md b/modification-enforcement.md new file mode 100644 index 0000000..945ebe4 --- /dev/null +++ b/modification-enforcement.md @@ -0,0 +1,98 @@ +For educational purposes only — not legal advice. + +# Modifying and Enforcing Washington Family Law Orders + +This book is for Washington State residents who already have final orders — a divorce decree, parenting plan, child support order, or spousal maintenance (alimony) order — and need to change one or make the other side follow it. Every statute cite was verified September 2026 against the official text at app.leg.wa.gov. + +## Modifying a parenting plan + +A parenting plan is a court order and cannot be changed just because you are unhappy with it. The court may not modify a parenting plan unless it finds, based on facts that arose after the plan was entered (or were unknown to the court then), that (a) a **substantial change has occurred in the circumstances of the child or the nonmoving parent**, and (b) the modification is **in the best interest of the child and necessary** to serve that interest (RCW 26.09.260(1)). A parent's military duties alone are not a substantial change (RCW 26.09.260(1)). + +Even with changed circumstances, the court **keeps the existing residential schedule** unless one of four things is shown (RCW 26.09.260(2)): + +1. The **parents agree**; +2. The child has been **integrated into the moving parent's family with the other parent's consent**, in substantial deviation from the plan; +3. The child's **present environment is detrimental** to the child's physical, mental, or emotional health, and the harm of a change is outweighed by its advantage to the child; or +4. The nonmoving parent has been found **in contempt at least twice within three years** for failing the residential provisions, or has been **convicted of custodial interference**. + +A custodial interference conviction (RCW 9A.40.060 or 9A.40.070) is itself a substantial change of circumstances (RCW 26.09.260(3)). The court may also reduce or restrict a parent's contact using the limitation criteria in RCW 26.09.191 and 26.09.192 (RCW 26.09.260(4)). + +### Minor modifications and nonresidential changes + +Smaller changes are easier. The court may make a **minor modification** to the residential schedule — one that does not change which parent the child lives with most of the time — on a substantial change in circumstances of **either parent or the child**, without the stricter factors above, if the change (RCW 26.09.260(5)): does not exceed **24 full days per calendar year**; results from the **non-primary parent moving** or an **involuntary work-schedule change** that makes the plan impractical; or adds up to no more than **90 overnights per year** when the plan does not give the non-primary parent reasonable time. A move by the parent the child lives with most is not a "minor modification" — that triggers the relocation rules below. Guardrails: a parent restricted under RCW 26.09.191 or 26.09.192 must show a change specifically related to the limitation (RCW 26.09.260(7)); a repeat 90-overnight motion within 24 months faces the stricter factors (RCW 26.09.260(5)); and a parent who has not completed court-ordered evaluations, treatment, or classes cannot expand time (RCW 26.09.260(9)). **Nonresidential aspects** of the plan (decision-making, dispute resolution) can be adjusted on a substantial change plus the child's best interest (RCW 26.09.260(10)). A **bad-faith motion** can cost the moving party the other parent's attorney fees and costs (RCW 26.09.260(13)). + +### The "adequate cause" gate and venue + +A party seeking to modify must submit an **affidavit setting forth facts** supporting the change; the court **denies the motion unless the affidavits establish "adequate cause"** for a hearing (RCW 26.09.270). The action may be filed in the county where the children live, the court that entered the order, or the county where the custodial parent lives (RCW 26.09.280). + +## Modifying child support + +A party may petition for child support modification based on **substantially changed circumstances at any time** (RCW 26.09.170(5)(a)). Two limits matter: modification applies **only to installments accruing after the petition** — no retroactive change (RCW 26.09.170(1)(a)) — and **voluntary unemployment or underemployment alone is not a substantial change** (RCW 26.09.170(5)(b)); a parent who quits or takes a voluntary pay cut may still have income imputed under the support schedule. + +Some modifications skip the changed-circumstances requirement: + +- **After one year**, an order may be modified without it for **severe economic hardship**, to extend support for a child still in high school past 18, or to add an **automatic adjustment** provision (RCW 26.09.170(8)). +- **After 24 months** from entry or the last adjustment, either party may seek adjustment based on **changed incomes or changes to the schedule's economic table**, by motion and worksheets (RCW 26.09.170(9)). A change over 30% causing significant hardship may be phased in two six-month steps (RCW 26.09.170(9)(c)). +- An order may be modified to add **incarceration abatement** (support reduced to $10 per month during confinement of six months or more) and again on release, without changed circumstances (RCW 26.09.170(6)–(7); RCW 26.09.320). +- **DCS** may seek modification when public assistance is paid or a review is requested, using a 15% deviation threshold (RCW 26.09.170(10)–(11)). + +**Procedure.** Modification begins with a **petition and worksheets**; the filing fee is $20 (RCW 26.09.175(1)). The response is due in **20 days** (60 days out of state) or default judgment follows (RCW 26.09.175(4)). The case is normally decided **on affidavits and worksheets alone**; oral testimony requires extraordinary circumstances, and testimony may be remote (RCW 26.09.175(6)–(8)). The decree itself may require **automatic periodic adjustments** (RCW 26.09.100), and the support schedule applies in every modification proceeding (RCW 26.19.035(1), (3)). + +## Modifying spousal maintenance + +Maintenance is harder to change than child support. A decree respecting maintenance may be modified **only as to installments accruing after the petition** and **only on a showing of a substantial change of circumstances** (RCW 26.09.170(1)). The **property division** may not be modified at all unless conditions exist that would justify reopening a judgment — rare (RCW 26.09.170(1)). Maintenance **ends automatically** on the death of either party, or on the recipient's remarriage or registration of a new domestic partnership, unless the decree or a written agreement says otherwise (RCW 26.09.170(2)). Cohabitation with a new partner is not, by statute, a termination event. + +## What is a "substantial change of circumstances"? + +It means something real and meaningful that has happened since the order. The statutory anchors: for **parenting plans**, a substantial change in the circumstances of the **child or the nonmoving parent** (RCW 26.09.260(1)); for **maintenance**, a substantial change judged against what the court contemplated when it made the award (RCW 26.09.170(1)(b)); for **child support**, "substantially changed circumstances" — with the carve-out that voluntary unemployment or underemployment alone does not qualify (RCW 26.09.170(5)) and the one-year and 24-month paths that skip the requirement (RCW 26.09.170(8)–(9)). In practice, qualifying changes are usually significant income changes, a parent's move, a child's changing needs, or a serious problem in the child's environment. + +## Relocation: when a move triggers modification + +Washington's relocation scheme, RCW 26.09.405 through 26.09.560, applies to plans entered after June 8, 2000, and older orders silent on relocation (RCW 26.09.405). "Relocate" means a change in the child's principal residence, permanent or protracted (RCW 26.09.410). + +**Notice.** A parent with majority residential time — or either parent in a substantially equal-time arrangement — must notify everyone entitled to residential time of an intended relocation (RCW 26.09.430). Notice is by personal service or return-receipt mail, at least **60 days before the move** (or within 5 days of learning the needed information), with specific reasons and a statutory warning that an objection must be filed within **30 days** or the move will be permitted (RCW 26.09.440). Failure to give notice is grounds for **sanctions, including contempt** (RCW 26.09.470). + +**Objecting.** The other parent files a petition to modify the parenting plan (or another adequate proceeding) within 30 days, plus a three-day mail waiting period (RCW 26.09.480(1)). Once an objection is filed, the relocating parent generally **may not move the child** without a court order, and a hearing noticed within 15 days freezes the move (RCW 26.09.480(2)). If no one objects in time, the relocation is **permitted** (except for good cause) and the proposed revised schedule takes effect (RCW 26.09.500). + +**The presumption.** There is a **rebuttable presumption the relocation will be permitted**; the objecting parent must show the move's detrimental effect outweighs its benefit to the child and the relocating person under eleven unweighted factors (RCW 26.09.520). But where parents have **substantially equal residential time** — 45% or more of the child's time with each parent — **there is no presumption**; the court decides in the child's best interests using the same factors (RCW 26.09.525). Relocation or objections made to harass or run up costs can draw **sanctions** (RCW 26.09.550); relocation hearings get docket priority (RCW 26.09.560). + +**The modification hook.** A relocation dispute is itself a modification pathway: either parent may petition to modify the plan — including changing the child's primary residence — **without showing adequate cause other than the proposed relocation itself**. The court first decides whether to permit or restrain the move, then what change to make to the plan (RCW 26.09.260(6)). + +## Enforcing parenting plans: contempt + +If the other parent violates the plan, the remedy is a **contempt action**. Self-help is barred: one parent's violation does **not suspend** the other's obligations, and conditioning support on residential time is bad faith (RCW 26.09.160(1)). A parent who in bad faith fails to comply with residential provisions faces (RCW 26.09.160(2)): + +- **Make-up time** equal to the time missed; +- Payment of the other parent's **court costs and reasonable attorney fees**; +- A **civil penalty of at least $100**; +- **Jail up to 180 days**, but only if the parent is presently **able** to comply and presently **unwilling**. + +A **second violation within three years** doubles the make-up time and raises the penalty to at least $250 (RCW 26.09.160(3)). Present ability to comply is **presumed**; the accused parent must prove inability or a reasonable excuse by a preponderance of the evidence (RCW 26.09.160(4)). Monetary awards are collected like civil judgments (RCW 26.09.160(5)). + +## Enforcing support: contempt and continuing jurisdiction + +A parent who fails to pay support or maintenance faces a contempt action under chapter 7.21 RCW: petition or motion, order to show cause, and — if warned and absent — a **bench warrant** (RCW 26.18.050(1)–(3)). A parent claiming inability to pay must prove **due diligence** in seeking employment or otherwise becoming able to comply (RCW 26.18.050(4)). The court **retains continuing jurisdiction** to enforce until **all arrearages are paid** — arrears do not vanish when the child turns 18 (RCW 26.18.050(5)). + +## Income withholding + +Support is normally paid by automatic **income withholding**. A wage-assignment or income-withholding order is available if the support order allows immediate withholding, or if the payer is **more than 15 days past due in an amount of at least one month's obligation** (RCW 26.18.070(1)). The court directs the order to the employer and the clerk forwards it to the **Washington State Support Registry** within five days (RCW 26.18.080). Support orders must state that withholding may be taken against wages, earnings, assets, or benefits without further notice (RCW 26.23.050). A withholding order can be quashed or modified only for **extreme hardship or substantial injustice**; after 12 consecutive months of current payments the payer may move to terminate it unless the recipient shows good cause (RCW 26.18.140). + +## Division of Child Support (DCS) + +The **Division of Child Support (DCS)** runs the State Support Registry and must provide enforcement services whenever public assistance is paid, whenever a parent applies, or when payments route through the registry (RCW 26.23.045(1)). Services continue until a court orders payments out of the registry (RCW 26.23.045(2)). DCS has administrative enforcement tools beyond court process and can also seek modification in court (RCW 26.09.170(10)–(11)). + +## License suspension for unpaid child support + +If a parent falls out of compliance, DCS may serve a **notice of noncompliance** with intent to suspend licenses (RCW 74.20A.320(1)). The parent has **20 days** to: pay the arrears in full; request an administrative hearing (RCW 74.20A.322); arrange a payment schedule (RCW 74.20A.326); or **file a court action to modify support**, which stays suspension up to six months (RCW 74.20A.320(2)(b)). Otherwise DCS certifies noncompliance to the Department of Licensing and other agencies, and the parent's **driver's license — plus fishing, hunting, and occupational licenses — is suspended or not renewed** until DCS issues a release (RCW 74.20A.320(2)(c)). Support orders must warn that licenses may be suspended for noncompliance (RCW 26.23.050). + +## Interest on unpaid support + +Judgments for unpaid child support bear **12% interest** (RCW 4.56.110(2)), and DCS may assess **12% per year** on unpaid support accrued under registry orders, unless the order specifies a different rate (RCW 26.23.030(2)). + +## Deadlines, back pay, and time limits + +- **No back pay.** Modification applies only to installments accruing after the petition or motion (RCW 26.09.170(1)(a)) — so file promptly, and note the duty to pay is not suspended by the other side's misconduct (RCW 26.09.160(1)). +- **No waiting period to modify.** Child support modification may be sought "at any time" (RCW 26.09.170(5)(a)); parenting plan modification has no fixed waiting period but must pass the adequate-cause gate (RCW 26.09.270). The one-year and 24-month windows only concern modifications made *without* proving changed circumstances (RCW 26.09.170(8)–(9)). +- **Child support arrears last longest.** Collection may be brought within **10 years of the youngest child's 18th birthday** (RCW 4.16.020(3)), with execution available in that window (RCW 6.17.020(2)) — extendable in 10-year increments (RCW 6.17.020(3)). +- **Other judgments — including maintenance arrearages** — are generally enforceable for **10 years from entry**, renewable for another 10 by application within 90 days before expiration, granted as a matter of right (RCW 6.17.020(1), (3); RCW 4.16.020(2)). No judgment is enforceable beyond 20 years from entry except as provided in RCW 4.16.020(2) or (3) (RCW 6.17.020(7)). +- **Relocation deadlines are strict.** The 60-day notice and 30-day objection clocks bind; missing the objection deadline can mean the move is permitted and the proposed schedule takes effect (RCW 26.09.440; RCW 26.09.500). diff --git a/overview-intake.md b/overview-intake.md new file mode 100644 index 0000000..1349404 --- /dev/null +++ b/overview-intake.md @@ -0,0 +1,123 @@ +# Washington Family Law: Court Process Overview and Intake + +> For educational purposes only — not legal advice. + +This book explains how a family law case (mainly divorce) actually moves through Washington's courts, who can file, what it costs, whether you need a lawyer, and which specialist to consult for which problem. It is written for Washington State residents in plain English. Sources: RCW statutes at app.leg.wa.gov, WashingtonLawHelp.org, courts.wa.gov, WSBA, and Legal Voice. All citations were verified September 2026. + +## The basics: what kind of case do you have? + +Washington family law cases are filed in **superior court**, not district court. A proceeding for dissolution of marriage (divorce), dissolution of a state-registered domestic partnership, legal separation, or a declaration concerning the validity of a marriage may be filed "in the superior court of the county where the petitioner resides" *(RCW 26.09.010(2))*. + +Washington is a **"no-fault" divorce state**. To get a divorce, you only need to allege that the marriage is "irretrievably broken" — you do not have to prove your spouse did anything wrong *(RCW 26.09.030; WashingtonLawHelp, "Divorce guide")*. If the other spouse denies the marriage is irretrievably broken, the court considers the circumstances and prospects for reconciliation, but can still enter a decree of dissolution *(RCW 26.09.030(1)(c))*. + +There is **no jury** in these cases — civil practice rules apply except that trial by jury is dispensed with *(RCW 26.09.010(1))*. + +A divorce case is titled "In re the marriage of ..." and the initial paperwork is called a **Petition**; the answering paperwork is a **Response** *(RCW 26.09.010(2), (4))*. + +## Residency requirements + +Washington's residency rules are among the most flexible in the country. A court can grant a divorce when the person filing (the petitioner) is any of the following: + +1. A resident of Washington State; +2. A member of the armed forces stationed in Washington State; or +3. Married (or in a registered domestic partnership) to a Washington resident or to an armed-forces member stationed here *(RCW 26.09.030)*. + +There is **no minimum length of time** you must live in Washington before filing — the statute requires only that you be a resident when you file, and it does not impose a waiting period of residence *(RCW 26.09.030)*. You also do not need to have been married in Washington *(RCW 26.09.030; WashingtonLawHelp, "Divorce guide")*. + +## The court process timeline + +A typical divorce in Washington moves through these stages *(WashingtonLawHelp, "Divorce guide", reviewed 05/07/2026; RCW 26.09.030)*: + +### Step 1 — Prepare and file the Petition + +You must use the official, state-approved family law forms — use of the approved forms is mandatory *(RCW 26.09.006)*. You can complete the forms free online through **Washington Forms Online** (a guided interview at courts.wa.gov) or download the packet from the "Dissolution (Divorce)" page at courts.wa.gov *(WashingtonLawHelp; courts.wa.gov/forms)*. + +### Step 2 — File with the Superior Court Clerk + +File the originals with the clerk in the county where the petitioner lives *(RCW 26.09.010(2))*. The clerk stamps your copies with the case number and filing date. Expect a filing fee (see "Court fees" below); many counties also allow electronic filing *(WashingtonLawHelp, "Divorce guide")*. + +### Step 3 — Serve the other spouse + +The other spouse must receive copies of the papers. Usually a third party personally serves them. Exceptions: your spouse can sign the "Service Accepted" form, or can sign an "Agreement to Join Petition" (joinder) if they agree to everything *(WashingtonLawHelp, "Divorce guide")*. + +- Your spouse typically has **20 days** to respond after in-state personal service *(WashingtonLawHelp)*. +- If served **outside Washington**, they have **60 days** *(RCW 4.28.180; WashingtonLawHelp)*. +- If served by mail or publication, they have **90 days** *(WashingtonLawHelp)*. + +If the respondent does not respond, you can ask the judge for an **order of default**, and the case can then be finished without the spouse's participation *(WashingtonLawHelp, "Divorce guide")*. + +### Step 4 — Temporary orders, if needed + +While the case is pending, either spouse can ask for temporary orders covering children, financial support, who pays which bills, use of property, and safety. The statute allows temporary maintenance or child support on motion with an affidavit, and temporary restraining orders or preliminary injunctions (for example, against disposing of property, disturbing the peace, or removing a child from the jurisdiction) *(RCW 26.09.060(1)–(6))*. + +### Step 5 — The 90-day waiting period + +Washington has a **mandatory 90-day waiting period**. The court cannot enter the final decree until **90 days have passed since the petition was filed AND since service of the summons** (or first publication) *(RCW 26.09.030)*. This is the minimum even if you and your spouse agree on everything; contested cases take longer *(WashingtonLawHelp, "Divorce guide")*. + +### Step 6 — Information gathering and settlement + +During the waiting period, spouses exchange financial information (informally or through formal "discovery"), negotiate, and often attend mediation or a settlement conference *(WashingtonLawHelp, "Divorce guide")*. Most cases settle. + +### Step 7 — Final orders + +- **By agreement:** both spouses sign the final orders (Findings, Decree, Parenting Plan, Child Support Order) and a judge reviews and signs them. +- **By default:** if the spouse never responded and default was entered. +- **By trial:** if you cannot agree, a judge decides at a trial. Some counties set a trial date when you file; others require you to request one *(WashingtonLawHelp, "Divorce guide")*. + +You are divorced when the judge **signs the Final Divorce Order and it is filed** with the clerk; the clerk then forwards a Certificate of Dissolution to the State Registrar of Vital Statistics *(WashingtonLawHelp, "Divorce guide")*. + +## Do you need a lawyer? + +You are **not required** to have a lawyer — many people file for divorce without one ("pro se"), using the free official forms *(courts.wa.gov/forms; RCW 26.09.006)*. However, WashingtonLawHelp strongly recommends talking with a lawyer before filing, because a divorce can affect rights you may not know about — for example, a share of your spouse's pension or retirement benefits that you could lose if not protected in the final orders *(WashingtonLawHelp, "Divorce guide")*. + +Middle options exist between full representation and going it alone: + +- **Advice-only or document review:** pay a lawyer to review your papers or advise you, without hiring them for the whole case *(WashingtonLawHelp, "Divorce basics")*. +- **Limited-scope ("unbundled") services:** hire a lawyer for one task only. Find lawyers offering these services through the WSBA's **Find Legal Help** page *(wsba.org/for-the-public/find-legal-help)*. +- **Reduced-fee help:** the WSBA **Moderate Means Program** connects moderate-income people with lawyers offering reduced fees in family law *(wsba.org)*. +- **Free legal aid:** low-income residents can call the **CLEAR hotline at 1-888-201-1014** (weekdays 9:15 a.m.–12:15 p.m.); **in King County call 2-1-1** *(Northwest Justice Project, nwjustice.org/clear-hotline)*. + +If your spouse has a lawyer, has significant assets or a pension, or if domestic violence is involved, obtaining a lawyer is especially important *(WashingtonLawHelp, "Divorce guide")*. + +## Court fees and fee waivers + +The base fee for filing the first document in a civil case (including divorce) is **$200** *(RCW 36.18.020(2)(a))*, plus statutory surcharges of **$40** and **$50** *(RCW 36.18.020(5)(c), (6))*. Counties with a courthouse facilitator program may add up to a **$20** surcharge on family law cases *(RCW 26.12.240)*. WashingtonLawHelp currently lists the total divorce filing fee as about **$364**, and notes superior court filing fees range from about $36 to $364 depending on case type — check your county clerk for the exact amount *(WashingtonLawHelp, "Divorce guide" and "Ask the court for a fee waiver", reviewed 05/07/2026)*. + +### Fee waivers (GR 34) + +If you cannot afford the fees, you can ask the judge to waive them under **General Rule 34**. You are eligible if you receive needs-based public benefits (TANF, SSI, SNAP/food stamps, federal poverty-related veterans' benefits, or similar), **or** your household income is **at or below 125% of the federal poverty guideline**, **or** your income is above that level but recurring basic living expenses leave you unable to pay, **or** other compelling circumstances exist *(GR 34; WashingtonLawHelp)*. A waiver covers **all required fees and surcharges**, and courts cannot charge a fee just to apply *(GR 34; WashingtonLawHelp, citing Jafar v. Webb)*. Optional services — such as mediation you choose or Guardian ad Litem fees — are generally **not** covered *(WashingtonLawHelp, "Ask the court for a fee waiver")*. Most protection order petitions are free to file *(WashingtonLawHelp)*. + +## Which specialist for which problem + +| Your problem | Who to consult | +|---|---| +| General divorce, property, parenting, trial | A **family law attorney** (wsba.org find-a-lawyer) | +| You and your spouse mostly agree; want help reaching an agreement | A **family law mediator** (see the companion book, "Mediation and ADR") | +| Child custody/parenting is contested; the court wants an independent view of the child's best interests | A **Guardian ad Litem (GAL)**, appointed by the court *(RCW 26.12.175)* | +| Court-ordered investigation of parenting arrangements (home studies, evaluations) | A court-ordered **parenting evaluator / investigator** *(RCW 26.09.220)* | +| Domestic violence, safety planning, protective orders | A **domestic violence advocate** through your local DV program; courts may connect parties to trained advocates *(RCW 26.09.016)*; National DV Hotline 1-800-799-7233 | +| Help filling out and filing forms without a lawyer | Your county's **courthouse facilitator** program, where available *(RCW 26.12.240)*; Washington Forms Online | +| Dividing retirement accounts, pensions, QDROs, business valuation | A **CPA or QDRO/retirement specialist** working with your attorney (practical guidance; not a statutory role) | +| Emotional support for you or the children | A licensed **therapist or counselor** (not a legal role; see Legal Voice resources) | + +## Where to get help + +- **WashingtonLawHelp.org** — free plain-language guides on divorce, custody, and support. +- **courts.wa.gov/forms** — official forms, instructions, and Washington Forms Online. +- **WSBA** (wsba.org/for-the-public/find-legal-help) — find a lawyer; Moderate Means Program. +- **CLEAR hotline** 1-888-201-1014 (weekdays 9:15 a.m.–12:15 p.m.); King County: 2-1-1. +- **Legal Voice** (legalvoice.org) — free legal rights resources. +- Your **county clerk or family law facilitator** for local procedures and fees. + +## Sources + +- RCW 26.09.010, .006, .016, .030, .060 — app.leg.wa.gov (Title 26, Chapter 26.09) +- RCW 4.28.180 (out-of-state service) — app.leg.wa.gov +- RCW 36.18.020 (clerk fees/surcharges) — app.leg.wa.gov +- RCW 26.12.240 (courthouse facilitator program) — app.leg.wa.gov +- GR 34 (fee waiver) — courts.wa.gov/court_rules/pdf/GR/GA_GR_34_00_00.pdf +- WashingtonLawHelp.org — "Divorce guide" and "Ask the court for a fee waiver" (both reviewed 05/07/2026) +- courts.wa.gov/forms — "Dissolution (Divorce)" forms page; Washington Forms Online / Guide & File +- wsba.org — "Find Legal Help" +- nwjustice.org — "CLEAR Hotline" +- legalvoice.org — legal resources for Washington residents diff --git a/parentage.md b/parentage.md new file mode 100644 index 0000000..f689312 --- /dev/null +++ b/parentage.md @@ -0,0 +1,95 @@ +For educational purposes only — not legal advice. + +# Parentage in Washington State: The Uniform Parentage Act + +## What Parentage Is and Why It Matters + +"Parentage" is the legal parent-child relationship. It is different from biology: biology matters in Washington, but it is not the only path to legal parentage — and sometimes not enough by itself. Once parentage is established, the relationship "applies for all purposes" — support, custody and parenting time, inheritance and benefits, medical decisions, and more — unless a different law says otherwise (RCW 26.26A.110). The law treats children of married and unmarried parents equally: "A parent-child relationship extends equally to every child and parent, regardless of the marital status of the parent" (RCW 26.26A.105). + +In practice, an unmarried father whose parentage was never legally established has no legal right to custody or parenting time and no enforceable duty of support; once parentage is established, both parents gain rights *and* obligations. Only Washington superior courts may adjudicate parentage (RCW 26.26A.030), under chapter 26.26A RCW — Washington's version of the Uniform Parentage Act (UPA). + +## Washington's Law: The Uniform Parentage Act + +The Washington Uniform Parentage Act took effect **January 1, 2019** (RCW 26.26A.903) and applies even to cases already pending then (RCW 26.26A.902). The act is officially titled the "uniform parentage act" (RCW 26.26A.005) and uses these gender-neutral terms: an **acknowledged parent** became a parent by signing an acknowledgment form; an **adjudicated parent** is one a court has declared a parent; an **alleged genetic parent** is someone alleged to be the genetic parent whose parentage is not yet established (RCW 26.26A.010). The chapter governs every determination of parentage (RCW 26.26A.020), and rules written for a "father" also apply to a mother, and vice versa (RCW 26.26A.060). + +## The Seven Ways Parentage Is Established + +The law lists seven ways a parent-child relationship comes into existence (RCW 26.26A.100): giving birth; being a presumed parent; being adjudicated a parent; adopting the child; signing an acknowledgment of parentage; becoming a parent through assisted reproduction; or becoming a parent through a surrogacy agreement. + +## Presumed Parents: Marriage, Domestic Partnership, and Four Years of Care + +Washington law presumes someone is a parent — without any paperwork or court order — in several situations (RCW 26.26A.115(1)): + +- The person was **married to, or in a state-registered domestic partnership with**, the person who gave birth, and the child is **born during** the marriage or partnership (RCW 26.26A.115(1)(a)(i)). +- The marriage or partnership ended (death, dissolution, annulment, invalidity, or legal separation), but the child is born **within 300 days** after it ended (RCW 26.26A.115(1)(a)(ii)). +- The couple **married or registered a domestic partnership after the birth**, and the person asserted parentage in a record filed with the state registrar of vital statistics, or agreed to be — and is — named as a parent on the birth record (RCW 26.26A.115(1)(a)(iii)). +- The person **lived in the same household with the child for the child's first four years** (allowing temporary absences) and openly held the child out as their own (RCW 26.26A.115(1)(b)). + +A presumption can be overcome — but only by a court adjudication or a valid denial of parentage, not by argument or by a DNA test alone (RCW 26.26A.115(2)). After the child turns four, a presumption is harder to overcome: the court can do so only if the presumed parent is not the genetic parent **and** never lived with the child **and** never held the child out as their own, or if the child has more than one presumed parent (RCW 26.26A.435(2)). + +## Acknowledgment of Parentage: The Hospital Form + +The most common path for unmarried parents is the **acknowledgment of parentage** — the form offered at the hospital after birth — signed by the person who gave birth and the alleged genetic father (or a presumed parent or intended parent) (RCW 26.26A.200). It must be notarized or witnessed, state that the child has no other presumed or acknowledged parent, and state that the signers understand it is the same as a court adjudication of parentage that can be challenged only in limited circumstances, with challenges barred four years after it takes effect (RCW 26.26A.205). It can be signed before birth and is valid even if signed by a minor; it takes effect on the later of the birth or the filing with the state registrar of vital statistics (RCW 26.26A.215). Once filed, it "is equivalent to an adjudication of parentage" and gives the acknowledged parent all the rights and duties of a parent (RCW 26.26A.220). The Department of Health may charge a filing fee (RCW 26.26A.225), though signing at the hospital shortly after birth (within five days) is typically free (DSHS Division of Child Support). + +A **denial of parentage** lets a presumed or alleged genetic parent state they are not the parent; it is valid only if someone else's acknowledgment is filed with it, it is notarized or witnessed, and the person has not previously acknowledged or been adjudicated a parent (RCW 26.26A.210). A valid denial is equivalent to an adjudication of nonparentage and discharges all parental rights and duties (RCW 26.26A.220(2)). + +**Backing out.** A signer may rescind an acknowledgment or denial by filing a rescission with the state registrar within **60 days** of the effective date, or before the first court hearing about the child in a case the signer is a party to — whichever comes first (RCW 26.26A.235). After 60 days, for up to **four years**, a signer can still challenge, but only for **fraud, duress, or material mistake of fact** (RCW 26.26A.240). + +## Genetic Testing + +In a parentage case, the court **must order genetic testing** if a party files a sworn statement alleging a reasonable possibility they are — or are not — the genetic parent (RCW 26.26A.310(1)). Testing cannot be ordered while the child is still in the womb (RCW 26.26A.310(3)), and a testing order is enforceable by contempt (RCW 26.26A.310(8)). Exception: when a presumed parent or de facto parent claim exists, or someone challenges an acknowledgment, the court **may deny** testing after weighing the best-interest factors in RCW 26.26A.460(1)–(2) (RCW 26.26A.310(6)). + +Testing must use methods experts reasonably rely on, at an accredited laboratory; a proper chain of custody makes results admissible without testimony (RCW 26.26A.315, .320). A person is identified as the genetic parent if testing shows at least a **99 percent probability of parentage** and a combined relationship index of at least 100 to 1 (RCW 26.26A.325(1)). A lab report is admissible in court; a party has 14 days to object (RCW 26.26A.425). If an alleged genetic parent **refuses** court-ordered testing, the court may adjudicate them the parent anyway (RCW 26.26A.430(2)(c)). Whoever requests testing generally pays up front; the Division of Child Support pays when it is providing services and may seek reimbursement (RCW 26.26A.330). + +## Parentage Court Actions (Paternity Cases) + +A parentage proceeding may be brought in superior court under the civil rules (RCW 26.26A.400). Those who can file include the child, the person who gave birth, anyone claiming to be a parent, anyone whose parentage is to be determined, the Division of Child Support, and adoption agencies (RCW 26.26A.405). A case may be started **before the child is born**, though any order is not enforced until birth (RCW 26.26A.480), and while it is pending the court can issue temporary child support, parenting-time, and protection orders (RCW 26.26A.470). + +A case against an alleged genetic parent or a presumed parent must be started **before the child turns 18** — after that, only the adult child can bring it (RCW 26.26A.430(1), .435(1)). The court adjudicates an alleged genetic parent who is identified by genetic testing, admits parentage, refuses testing, defaults, or is found a parent on other evidence (RCW 26.26A.430(2)). The final order must identify the child, and the court may assess filing fees, attorney fees, and testing costs (RCW 26.26A.510); the signers and parties — and in some cases the child — are bound by the result (RCW 26.26A.515). One protection: a parent may ask the court to **preclude a person who committed sexual assault resulting in the pregnancy** from establishing parentage (RCW 26.26A.465). + +## De Facto Parentage + +Washington recognizes parents of the heart. A person who is not a biological or adoptive parent can be adjudicated a **de facto parent** if they prove seven things by a preponderance of the evidence (RCW 26.26A.440(4)): + +1. They resided with the child as a regular member of the household for a significant period. +2. They engaged in consistent caretaking. +3. They undertook full, permanent parental responsibilities without expecting pay. +4. They held the child out as their own. +5. They established a bonded, dependent relationship with the child that is parental in nature. +6. Another parent fostered or supported that bonded relationship. +7. Continuing the relationship is in the child's best interest. + +The claim must be filed before the child turns 18 and while the child is alive, with a verified pleading setting out specific facts; the court decides standing on an expedited basis (RCW 26.26A.440(2)–(3)). When two or more people have competing claims — for example, a presumed parent and a genetic parent — the court decides **in the best interest of the child**, weighing the child's age, how long each person acted as a parent, the nature of each relationship, the harm if a relationship is not recognized, the basis of each claim, and other equitable factors (RCW 26.26A.460(1)). Notably, a Washington court **may recognize more than two parents** if failing to do so would be detrimental to the child (RCW 26.26A.460(3)). + +## Assisted Reproduction and Surrogacy + +Washington has clear rules for families built with reproductive technology. A **sperm or egg donor is not a parent** of a child conceived by assisted reproduction (RCW 26.26A.605), while a person who **consents to assisted reproduction with the intent to be a parent is a parent** (RCW 26.26A.610). Consent should be in a written record signed by the person giving birth and the intended parent; even without a record, the court can find consent by clear and convincing evidence of a pre-conception agreement, or if the two lived together with the child for its first four years and both held the child out as their own (RCW 26.26A.615). Consent can be withdrawn in writing any time **before** the transfer that results in pregnancy (RCW 26.26A.630). If an intended parent dies between the transfer and the birth, their parentage can still be established (RCW 26.26A.635). + +Surrogacy agreements are legal in Washington but heavily regulated: the surrogate must be at least 21, have previously given birth, and complete medical and mental-health evaluations with independent counsel (RCW 26.26A.705). In a **gestational** surrogacy (the surrogate is not genetically related to the child), each intended parent is a parent **by operation of law** at birth, and the surrogate and her spouse are not parents (RCW 26.26A.740). Separate validation rules govern **genetic** surrogacy agreements (RCW 26.26A.760 through 26.26A.785), and the chapter also regulates information about gamete and embryo donors (RCW 26.26A.800 through 26.26A.825). + +## Unmarried Parents' Rights + +An unmarried mother is a parent from the moment of birth — no paperwork needed (RCW 26.26A.100(1)). An unmarried father is only an **alleged genetic parent** until parentage is established; the law treats children of unmarried and married parents identically (RCW 26.26A.105). Practical routes: sign an **acknowledgment** at the hospital or later (RCW 26.26A.200), ask the **Division of Child Support** for free help (RCW 26.26A.405(5)), or file a **Petition to Decide Parentage** in superior court using the free state-approved forms (RCW 26.26A.400). Once parentage exists, both parents have equal standing to seek parenting time and decision-making — and both owe support. + +## Why Parentage Matters for Custody and Child Support + +Parentage is the gatekeeper to everything else in a family case. A parentage adjudication or acknowledgment creates the legal relationship "for all purposes" (RCW 26.26A.110), which means: + +- **Custody and parenting time.** Only a legal parent can ask for a parenting plan (chapter 26.09 RCW); in a parentage action the court can issue temporary parenting-time orders (RCW 26.26A.470) and a final parenting plan. +- **Child support.** Only a legal parent owes — and can receive — child support, calculated under the Washington State Child Support Schedule in chapter 26.19 RCW. The Division of Child Support establishes parentage precisely so it can collect support (RCW 26.26A.405(5)). +- **Everything else.** Inheritance, benefits, insurance, and medical decisions flow from the parent-child relationship (RCW 26.26A.110). + +If you are unsure whether parentage has been established, the free "Parentage guide" at WashingtonLawHelp.org explains the options, and the Division of Child Support can help without a lawyer. + +## Key Citations + +- Uniform Parentage Act short title and effective date — RCW 26.26A.005, .903 +- Definitions — RCW 26.26A.010 +- Establishment of parent-child relationship (seven paths) — RCW 26.26A.100 +- Presumption of parentage — RCW 26.26A.115 +- Acknowledgment and denial of parentage — RCW 26.26A.200 through 26.26A.265 (rescission: .235; challenge: .240) +- Genetic testing — RCW 26.26A.300 through 26.26A.355 (ordering: .310; results: .325) +- Proceedings to adjudicate parentage — RCW 26.26A.400 through 26.26A.515 (standing: .405; de facto parentage: .440; competing claims: .460; temporary orders: .470) +- Assisted reproduction — RCW 26.26A.600 through 26.26A.635 +- Surrogacy agreements — RCW 26.26A.700 through 26.26A.785 +- Donor information — RCW 26.26A.800 through 26.26A.825 diff --git a/property-debt.md b/property-debt.md new file mode 100644 index 0000000..ef231e4 --- /dev/null +++ b/property-debt.md @@ -0,0 +1,117 @@ +For educational purposes only — not legal advice. + +# Community Property and Debt Division in Washington State + +Washington is a community property state — one of only a small number of states where most property and debts acquired during a marriage are owned equally by both spouses. Understanding the difference between "community" and "separate" property matters for divorce, debt collection, bankruptcy, and death. This book explains the basic rules. + +## What Is Community Property? + +**Property acquired during marriage is community property.** Under RCW 26.16.030, property that is not separate property and is acquired after marriage (or after registration of a state registered domestic partnership) by either spouse — or both — is community property. The law treats both spouses as having equal ownership, regardless of whose name is on the title or who earned the money. + +- Both spouses can manage and control community property (RCW 26.16.030). +- Neither spouse can give away community property without the other's consent (RCW 26.16.030(2)). +- Neither spouse can sell, convey, or mortgage community real estate without the other spouse signing the deed or document (RCW 26.16.030(3)). +- Neither spouse can will away more than half of the community property (RCW 26.16.030(1)). +- State registered domestic partners are treated the same as spouses throughout this chapter (RCW 26.16.030). + +**The key questions:** (1) When was the property acquired — before or during the marriage? (2) How was it acquired — by work, or by gift or inheritance? + +## What Is Separate Property? + +**Separate property belongs to one spouse only.** Under RCW 26.16.010, separate property is: + +- Property owned before the marriage. +- Property acquired during the marriage by gift, bequest, devise, descent, or inheritance. +- The rents, issues, and profits of that separate property (RCW 26.16.010). + +The same rule applies to registered domestic partners (RCW 26.16.020). + +Separate property is **not** subject to the debts or contracts of the other spouse, and the owner can manage, sell, or encumber it without the other spouse joining in (RCW 26.16.010). + +**Earnings while living apart.** Once spouses are living separate and apart, each spouse's earnings and accumulations are that spouse's separate property (RCW 26.16.140). This matters when a marriage breaks down before the divorce is filed. + +## Characterizing Common Assets + +The general rules produce the following results: + +- **Wages, salaries, and business income earned during the marriage** are community property (RCW 26.16.030). +- **A house or car bought during the marriage with earned money** is community property, even if only one name is on the title (RCW 26.16.030). +- **A house or car owned before the marriage** is separate property, but if community money is used to pay down the mortgage during the marriage, the community may acquire an interest — a tracing question courts resolve on the facts (RCW 26.16.010; RCW 26.16.030). +- **Gifts and inheritances received during the marriage** are separate property of the recipient, including what that property earns (RCW 26.16.010). +- **Personal injury settlements** may be community or separate depending on what the award compensates — this is case-law-driven; see WashingtonLawHelp.org's community property guide (linked below) for the practical explanation. +- **Retirement and pension benefits** earned during the marriage are property that can be divided at divorce, even if the benefits will not be paid until later (In re Marriage of Brown, 98 Wn.2d 46, 653 P.2d 602 (1982)). + +A spouse can change the character of property — for example, by transferring separate property into community property by agreement or gift. Washington case law generally allows spouses to change the character of property by their intent shown through words or conduct, subject to protecting creditors (see RCW 26.16.210 on the burden of proving good faith in transactions between spouses). + +## Community Property Agreements + +Spouses can make a written agreement that changes the status or disposition of all or part of their community property, to take effect on the death of either spouse. The agreement must be in writing, witnessed and acknowledged like a deed to real estate. It cannot defeat the rights of creditors, and a court can set it aside for fraud or other recognized equity grounds (RCW 26.16.120). This is a planning tool for married couples, not a way to hide assets from creditors. + +## Debts: Who Owes What? + +**Family expenses are chargeable to both spouses.** Expenses of the family and education of the children (including stepchildren) are chargeable upon the property of both spouses or either of them, and the spouses may be sued jointly or separately (RCW 26.16.205). + +**Premarital debts.** Neither spouse is liable for debts the other incurred before the marriage, nor for the other's separate debts. The non-debtor spouse's separate property and the income from it are not available for those debts. However, the debtor spouse's own earnings and accumulations can be reached by creditors for premarital debts (RCW 26.16.200). + +**The three-year judgment rule for separate debts.** A separate debt (other than child support or maintenance) cannot be collected against either spouse's earnings and accumulations unless the creditor reduces it to a judgment within three years of the marriage (RCW 26.16.200). + +**Child support is different.** A parent's or stepparent's child support obligation can be collected from that person's separate property, earnings, and share of the community property. But funds in a community bank account that can be identified as the earnings of the non-obligated spouse are exempt from satisfying the debtor spouse's child support obligation (RCW 26.16.200). + +**Torts (injuries).** If one spouse causes an injury, there is no recovery against the separate property of the other spouse, except where the other spouse would be jointly responsible even without the marriage (RCW 26.16.190). + +**General rule for debts incurred during marriage.** Debts incurred by either spouse during the marriage for family or community purposes are community obligations for which community property can be reached — the statutes carve out only premarital debts, separate debts, and the other spouse's separate property (RCW 26.16.200; RCW 26.16.205). WashingtonLawHelp.org's community property and debt resources explain how this plays out with creditors. + +## Dividing Property and Debts in Divorce + +**The standard is "just and equitable" — not necessarily 50/50.** In a dissolution, legal separation, or declaration of invalidity, the court must divide the property and liabilities of the parties — both community and separate — as appears just and equitable, **without regard to marital misconduct** (RCW 26.09.080). The court considers, among other relevant factors: + +1. The nature and extent of the community property. +2. The nature and extent of the separate property. +3. The duration of the marriage. +4. The economic circumstances of each spouse when the division takes effect, including the desirability of awarding the family home — or the right to live in it — to the spouse with whom the children live the majority of the time (RCW 26.09.080(1)–(4)). + +Key practical points: + +- **The court can divide separate property too.** RCW 26.09.080 expressly covers "either community or separate" property. +- **Debts are divided in the same proceeding.** The court's disposition covers "the liabilities of the parties" (RCW 26.09.080). +- **The division is between the spouses.** A divorce decree allocating a debt does not by itself stop a creditor from pursuing either spouse under the debt rules above; the decree gives the paying spouse rights against the other spouse. (See the creditor/debt statutes cited above and WashingtonLawHelp.org's debt resources.) +- **Maintenance (alimony) is a separate question.** Spousal support is decided under RCW 26.09.090 based on its own factors (financial resources, time needed for education or training, standard of living, duration of the marriage, age and health, and the paying spouse's ability to pay). +- **Property division is usually final.** After the decree, courts have limited power to reopen property division — a party should not assume the division can be changed later. + +## Separation Contracts + +Spouses can settle property, debts, support, and parenting issues by a written separation contract. In a later dissolution, the contract (except parenting plan terms) is binding on the court unless it finds the contract was unfair at the time it was executed (RCW 26.09.070). Such contracts are common and generally enforced. + +## Unmarried Couples: Committed Intimate Relationships + +Community property law applies only to married couples and registered domestic partners (RCW 26.16.030). Unmarried couples who live together are governed instead by the "committed intimate relationship" (CIR) doctrine — previously called "meretricious relationship" law. + +Under Connell v. Francisco, 127 Wn.2d 339 (1995), when a stable, marriage-like relationship ends, the court can divide property acquired during the relationship in a just and equitable manner. Courts look at factors including: continuous cohabitation, the duration of the relationship, the purpose of the relationship, the pooling of resources and services for joint projects, and the intent of the parties (Connell, 127 Wn.2d at 346). WashingtonLawHelp.org has a dedicated "Committed Intimate Relationships" topic with practical guidance. + +## Quasi-Community Property + +"Quasi-community property" is property acquired while the couple lived in another state that **would have been** community property if Washington law had applied at acquisition. It matters mainly at death: half of the quasi-community property belongs to the surviving spouse, and half passes by will or intestacy as community property would (RCW 26.16.220; RCW 26.16.230). + +## Where to Get Help + +- **WashingtonLawHelp.org** — free plain-English guides: "Community Property in Washington State" (https://www.washingtonlawhelp.org/resource/community-property-in-washington-state) and "Divorce in Washington State" (https://www.washingtonlawhelp.org/resource/divorce-in-washington-state). +- **Washington State Courts** — court forms and self-help information: https://www.courts.wa.gov/forms/. +- **Washington State Bar Association** — lawyer referral and legal help resources: https://www.wsba.org/. + +## Sources + +- RCW 26.16.010, 26.16.020 (separate property) — app.leg.wa.gov +- RCW 26.16.030 (community property defined; management and control) — app.leg.wa.gov +- RCW 26.16.120 (community property agreements) — app.leg.wa.gov +- RCW 26.16.140 (earnings while living apart) — app.leg.wa.gov +- RCW 26.16.190 (tort liability between spouses) — app.leg.wa.gov +- RCW 26.16.200 (premarital and separate debts) — app.leg.wa.gov +- RCW 26.16.205 (family expense liability) — app.leg.wa.gov +- RCW 26.16.210 (burden of proof in interspousal transactions) — app.leg.wa.gov +- RCW 26.16.220, 26.16.230 (quasi-community property) — app.leg.wa.gov +- RCW 26.09.070 (separation contracts) — app.leg.wa.gov +- RCW 26.09.080 (disposition of property and liabilities — factors) — app.leg.wa.gov +- RCW 26.09.090 (maintenance — factors) — app.leg.wa.gov +- In re Marriage of Brown, 98 Wn.2d 46, 653 P.2d 602 (1982) (pensions as divisible property) +- Connell v. Francisco, 127 Wn.2d 339 (1995) (committed intimate relationships) +- WashingtonLawHelp.org; Washington State Courts (courts.wa.gov); WSBA (wsba.org) diff --git a/protection-orders.md b/protection-orders.md new file mode 100644 index 0000000..7e3c09e --- /dev/null +++ b/protection-orders.md @@ -0,0 +1,122 @@ +For educational purposes only — not legal advice. + +# Protection Orders in Washington State + +Washington law gives people a fast, free civil court process to get protection from violence, harassment, stalking, sexual assault, and firearm danger. Since July 1, 2022, all protection orders are governed by one consolidated statute — chapter 7.105 RCW — which replaced and recodified the older separate laws, including the Domestic Violence Prevention Act (former chapter 26.50 RCW) and parts of the stalking protection order law (former chapter 26.52 RCW). The recodification took effect July 1, 2022 (see RCW 7.105.900; 2021 c 215). + +## The Six Types of Protection Orders + +RCW 7.105.100(1) establishes six types of protection order petitions: + +1. **Domestic violence protection order (DVPO)** — requires domestic violence by an intimate partner or a family or household member (RCW 7.105.100(1)(a)). +2. **Sexual assault protection order** — requires nonconsensual sexual conduct, nonconsensual sexual penetration, or commercial sexual exploitation. A single incident is enough. No relationship to the respondent is required (RCW 7.105.100(1)(b)). +3. **Stalking protection order** — requires stalking. No relationship required (RCW 7.105.100(1)(c)). +4. **Vulnerable adult protection order** — requires that the protected person is a vulnerable adult who has been abandoned, abused, financially exploited, or neglected, or is threatened with those harms (RCW 7.105.100(1)(d)). +5. **Extreme risk protection order (ERPO)** — requires that the respondent poses a significant danger of injuring self or others with a firearm. Only an intimate partner, a family or household member, or a law enforcement agency can file (RCW 7.105.100(1)(e)). +6. **Antiharassment protection order** — requires unlawful harassment (a knowing and willful course of conduct, or a single violent act or threat, that seriously alarms the petitioner and serves no lawful purpose). No relationship required (RCW 7.105.100(1)(f); RCW 7.105.010(37)). + +The court cannot dismiss a petition just because the conduct would also fit another order type — it must consider the petitioner's preferred type (RCW 7.105.100(5)). + +## Key Definitions + +- **Domestic violence** means physical harm, bodily injury, assault, or the infliction of fear of those harms; nonconsensual sexual conduct or penetration; coercive control; unlawful harassment; or stalking — committed by an intimate partner or a family or household member (RCW 7.105.010(10)). +- **Coercive control** means a pattern of behavior used to cause physical, emotional, or psychological harm that unreasonably interferes with a person's free will and personal liberty. Examples include property destruction, technology abuse, weapon intimidation, isolation, and psychological aggression (RCW 7.105.010(4)). +- **Family or household members** include people related by blood, marriage, domestic partnership, or adoption; people who currently or formerly lived together; people with a parent-child relationship (including stepparents, stepchildren, grandparents, grandchildren); and a person who is acting or has acted as a legal guardian (RCW 7.105.010(14)). +- **Intimate partners** include spouses and former spouses, domestic partners and former domestic partners, people who share a child (unless conceived through sexual assault), and people 13 or older who have or had a dating relationship (RCW 7.105.010(21)). A **dating relationship** is a social relationship of a romantic nature (RCW 7.105.010(9)). +- **Stalking** includes stalking under RCW 9A.46.110 and cyber harassment under RCW 9A.90.120 (RCW 7.105.010(35)). +- **Vulnerable adult** includes a person 60 or older who cannot care for themselves, or an adult under guardianship or conservatorship (RCW 7.105.010(38)). + +## Who Can File + +- Any adult can file for themselves; **minors 15 and older** can file without an adult (RCW 7.105.100(2)). +- Children under 15 must petition through an authorized adult (RCW 7.105.100(3)). +- A petitioner may also ask for protection of minor children and vulnerable adults in the household (RCW 7.105.100(1)(a)). +- Leaving your home does not affect your right to petition (RCW 7.105.105(7)). + +## How to File: Where, Cost, and Forms + +- Petitions may be filed in superior court or in district/municipal court, in person or electronically; filing systems must accept submissions any time of day (RCW 7.105.105(1)). Vulnerable adult protection orders are filed **only** in superior court (RCW 7.105.065). +- **No filing fees** are charged for protection order petitions — except antiharassment orders, which may carry a fee unless the respondent committed stalking, a hate crime, a violent act, sexual assault, or domestic violence, or the petitioner cannot pay (RCW 7.105.105(9)). +- No bond is required, service is free, and certified copies and forms are provided free of charge (RCW 7.105.105(8)–(9)). +- The petition must be signed under penalty of perjury and must disclose other pending litigation or existing protection/no-contact orders (RCW 7.105.105(3)–(4)). +- The petitioner may keep their address confidential if disclosing it would risk harm (RCW 7.105.105(10)). +- Standard forms are on the Washington Courts website: the Protection Orders packet (https://www.courts.wa.gov/forms/?fa=forms.contribute&formID=142) and the Extreme Risk Protection Order forms (https://www.courts.wa.gov/forms/?fa=forms.contribute&formID=106). + +## Temporary (Ex Parte) Orders + +A petitioner can ask for an immediate **ex parte temporary protection order** — issued without notice to the respondent — when serious immediate harm or irreparable injury could result before a hearing. The court may issue it the same day the petition is filed, and must review ex parte requests as a priority, no later than the following judicial day (RCW 7.105.305(1); RCW 7.105.105(12)). + +- The temporary order is initially valid for up to **14 days**, extendable for good cause (RCW 7.105.100(8)). +- The full hearing must be set **within 14 days** of filing (RCW 7.105.305(4)). +- There is a rebuttable presumption that the petitioner's minor children are included in a temporary DVPO (RCW 7.105.100(8)). + +## What an Order Can Do + +RCW 7.105.310 lists the relief a court may grant, including: + +- Restraining the respondent from violence, threats, stalking, harassment, and any contact — direct, indirect, or through third parties (RCW 7.105.310(1)(a)–(b)). +- Excluding the respondent from the shared residence, and from the petitioner's residence, workplace, school, or a child's school or day care (RCW 7.105.310(1)(c)–(d)). +- A distance restriction, presumptively at least **1,000 feet** from protected people and places (RCW 7.105.310(1)(e)). +- Temporary residential provisions for shared children, and suspending the respondent's contact under an existing parenting plan, without requiring a full parenting plan (RCW 7.105.310(1)(f)). +- Ordering perpetrator treatment, mental health or chemical dependency evaluation, electronic monitoring, use of a vehicle, and possession of essential personal effects — including pets (RCW 7.105.310(1)(g), (h), (l), (n), (o)). +- Requiring the respondent to pay court costs, service fees, and the petitioner's reasonable attorney fees (RCW 7.105.310(1)(j)). +- Ordering surrender of firearms, dangerous weapons, and any concealed pistol license (RCW 7.105.310(1)(m); RCW 9.41.800). +- Restricting abusive litigation and harassing filings (RCW 7.105.310(1)(p)). + +## Firearms Surrender + +When a qualifying protection order issues, the court must consider RCW 9.41.800 and order the respondent to surrender all firearms, dangerous weapons, and any concealed pistol license, and prohibit possessing, purchasing, or receiving them (RCW 7.105.310(1)(m); RCW 9.41.800). Orders that include weapons surrender require personal service by law enforcement (RCW 7.105.150(1)(a)–(b)). Law enforcement may stand by to help the petitioner recover possessions and firearms (RCW 7.105.320). + +## The Full Hearing + +At the full hearing, the court issues the order if the petitioner proves the required conduct by a **preponderance of the evidence** (more likely than not) (RCW 7.105.225(1)). The court may not deny a petition merely because the petitioner is a minor, did not report to police, has other court orders available, or there is another pending proceeding (RCW 7.105.225(2)). + +## Duration and Renewal + +- A full order is for a **fixed period of at least one year** (unless the petitioner requests a shorter period) or may be **permanent** (RCW 7.105.315(1)). A provision restraining contact with the respondent's own minor children is limited to one year (RCW 7.105.315(2)). +- The petitioner may file for renewal any time in the **90 days before expiration**. The hearing is set within 14 days. The petitioner does **not** need to prove current fear; the order is renewed unless the respondent proves a substantial change in circumstances and that the prohibited conduct will not resume. Renewals are for at least one year or permanent (RCW 7.105.405(1)–(4), (8)). +- The court may not deny renewal just because the respondent never violated the order, time passed, or the respondent moved away (RCW 7.105.405(6)). + +## Violations: Enforcement and Penalties + +- Violating restraint, exclusion, or distance provisions of a DVPO, sexual assault, stalking, or vulnerable adult order is a **gross misdemeanor** (RCW 7.105.450(1)). +- Police **must arrest without a warrant** anyone they have probable cause to believe violated those provisions (RCW 7.105.450(2)). +- An **assault that violates the order is a class C felony**, as is reckless conduct creating substantial risk of death or serious injury; a third violation (with two prior convictions) is also a class C felony (RCW 7.105.450(4)–(5)). +- A violation is also **contempt of court**, and the court can issue a show-cause order within 14 days (RCW 7.105.450(3), (7)). +- The respondent must know of the order to be penalized; police serve the order if needed (RCW 7.105.465). +- Clerks and law enforcement enter orders into statewide systems and the federal background check system the same or next judicial day; the order is enforceable statewide (RCW 7.105.325). + +## Modification and Termination + +A respondent can ask the court to modify or terminate a DVPO, sexual assault, stalking, or antiharassment order, but only once every 12 months, and the respondent must prove by a preponderance of the evidence a substantial change in circumstances showing the prohibited conduct will not resume. The petitioner has no burden to prove ongoing fear. The court may refuse to terminate a severe-order case regardless (RCW 7.105.500). + +## Extreme Risk Protection Orders (ERPOs) + +ERPOs address firearm danger, not necessarily abuse of the petitioner: + +- Grounds: the respondent poses a **significant danger of causing personal injury to self or others** with a firearm (RCW 7.105.100(1)(e)). +- A temporary ERPO issues on **reasonable cause** after an ex parte review, and the full hearing follows; a full ERPO can last **one year** (RCW 7.105.330(2)–(3)). +- The court considers evidence including recent threats or violence, patterns within the past 12 months, violations of other orders, and firearm access (RCW 7.105.215(3)). +- The respondent must surrender all firearms and any concealed pistol license to law enforcement immediately; the license is revoked (RCW 7.105.340). +- The respondent can request a termination hearing once every 12 months and bears the burden of proving they do not pose a significant danger (RCW 7.105.505). +- Filing a knowingly false ERPO petition, or possessing a firearm while subject to an ERPO, is a gross misdemeanor; a repeat firearms violation is a class C felony (RCW 7.105.460). +- Surrendered firearms are returned only after a background check confirms eligibility and the order has ended (RCW 7.105.345). + +## The Older Laws (Recodification Note) + +Before July 1, 2022, domestic violence protection orders lived in chapter 26.50 RCW (the Domestic Violence Prevention Act) and stalking orders in chapter 26.52 RCW. Chapter 7.105 RCW, enacted by Laws of 2021, ch. 215, consolidated and recodified those laws effective July 1, 2022 — for example, former RCW 26.50.100 and 26.50.110 were repealed by 2021 c 215 § 170, effective July 1, 2022, and former RCW 26.52.070 now directs that violations be punished under RCW 7.105.450. Older cases and forms citing chapter 26.50 RCW are still useful background, but current citations should use chapter 7.105 RCW. + +## If You Need an Order Right Now + +1. **If you are in immediate danger, call 911.** Violations of qualifying orders require mandatory arrest (RCW 7.105.450(2)). +2. **Get forms and instructions** from the Washington Courts Protection Orders page (https://www.courts.wa.gov/forms/?fa=forms.contribute&formID=142) or at any courthouse — there is no filing fee in almost all cases (RCW 7.105.105(9)). +3. **Ask about advocacy help.** Domestic violence advocates at courthouses and community programs can help complete the paperwork. Free legal information is available from WashingtonLawHelp.org (see its "Protection Orders (2022 and later)" resource, https://www.washingtonlawhelp.org/resource/protection-orders-2022-and-later) and Legal Voice (https://www.legalvoice.org/). The National Domestic Violence Hotline is available 24/7 at 1-800-799-7233. +4. **Keep a certified copy of the order with you**, and report any violation to police; you can be protected even if you initiated contact — the order's provisions are on the respondent, and only the court can change the order (RCW 7.105.115(1)(a)). + +## Sources + +- Chapter 7.105 RCW (Civil Protection Orders) — app.leg.wa.gov (sections cited throughout: 7.105.010, 7.105.065, 7.105.100, 7.105.105, 7.105.110, 7.105.115, 7.105.150, 7.105.215, 7.105.225, 7.105.305, 7.105.310, 7.105.315, 7.105.320, 7.105.325, 7.105.330, 7.105.335, 7.105.340, 7.105.345, 7.105.350, 7.105.405, 7.105.450, 7.105.460, 7.105.465, 7.105.500, 7.105.505, 7.105.900) +- RCW 9.41.800 (firearms surrender) — app.leg.wa.gov +- Former chapters 26.50 and 26.52 RCW (recodified/repealed effective July 1, 2022 by 2021 c 215) — app.leg.wa.gov +- Washington State Courts — Protection Order forms (courts.wa.gov) +- WashingtonLawHelp.org; Legal Voice (legalvoice.org) diff --git a/spousal-maintenance.md b/spousal-maintenance.md new file mode 100644 index 0000000..e995194 --- /dev/null +++ b/spousal-maintenance.md @@ -0,0 +1,98 @@ +# Spousal Maintenance (Alimony) in Washington State + +> For educational purposes only — not legal advice. + +## What spousal maintenance is + +Spousal maintenance — what many people call **alimony** or spousal support — is money one spouse is ordered to pay the other for financial support when a marriage or registered domestic partnership ends. Washington law uses the word **maintenance** (WashingtonLawHelp.org, *Divorce guide*). + +Maintenance is **not automatic** and **not calculated by a formula**. A judge decides whether to award it, in what amount, and for how long, by weighing the factors in the statute (RCW 26.09.090). Either spouse — and either domestic partner — may be ordered to pay or may receive maintenance; there is no gender-based rule (RCW 26.09.090(1)). + +Maintenance is separate from **child support**, which is money for raising children under 18 and is calculated under the Washington State Child Support Schedule in Chapter 26.19 RCW. A person can receive maintenance, child support, both, or neither. + +## When maintenance can be awarded + +A court may grant a maintenance order in any of these proceedings (RCW 26.09.090(1)): + +- Dissolution of marriage or domestic partnership (divorce); +- Legal separation; +- Declaration of invalidity (annulment) — the court has the same authority to award maintenance in an annulment case (RCW 26.09.040(3)); and +- A later maintenance proceeding where a divorce was granted by a court that lacked personal jurisdiction over the absent spouse. + +Maintenance can also be **temporary**: while a divorce is pending, either party can ask the judge for temporary maintenance with a motion and affidavit stating the facts and amounts requested (RCW 26.09.060(1)). Temporary orders end when the final decree is entered (RCW 26.09.060(10)(c)). + +## The six factors a judge considers + +When deciding maintenance, the court must consider all relevant factors, including but not limited to these six, from RCW 26.09.090(1), translated into plain English: + +1. **The requesting spouse's financial resources** — the money and property the person asking for maintenance will have after the divorce, including any property awarded in the property division, and the ability to meet their own needs independently. The court also looks at whether child support received for a child living with that spouse already covers part of that spouse's needs (RCW 26.09.090(1)(a)). +2. **Time needed for education or training** — how long it would take the requesting spouse to get education or training to find work appropriate to their skills, interests, standard of living, and circumstances (RCW 26.09.090(1)(b)). +3. **The standard of living during the marriage** (RCW 26.09.090(1)(c)). +4. **The length of the marriage or domestic partnership** (RCW 26.09.090(1)(d)). +5. **The age, physical and emotional condition, and financial obligations** of the spouse requesting maintenance (RCW 26.09.090(1)(e)). +6. **The paying spouse's ability to pay** — whether the other spouse can meet their own needs and obligations while also paying maintenance (RCW 26.09.090(1)(f)). + +Two things the court is told not to consider: misconduct (fault) is irrelevant — the order is made "without regard to misconduct" (RCW 26.09.090(1)) — and there is no presumption that maintenance must be awarded. The court "may" grant it, in "such amounts and for such periods of time as the court deems just" (RCW 26.09.090(1)). + +## Who is likely to receive maintenance — practical picture + +Because there is no formula, results vary case by case. WashingtonLawHelp.org's *Divorce guide* describes the practical pattern: + +- Maintenance is **more likely** when the marriage was long, when the requesting spouse has a disability or stayed home to care for children while the other spouse worked, and when that spouse would have trouble finding a good job now. +- Being unemployed for a **long time** (especially after staying home with children) supports an award more than a temporary layoff. +- Maintenance is possible **even if the requesting spouse is working**, if the judge decides the paying spouse can afford it and the requesting spouse should be able to keep the standard of living established during the marriage. +- The judge weighs how long you were married, both spouses' financial situations after property and debt division, the time needed for education or training, the marital standard of living, and the age and health of the requesting spouse. + +The factors from the statute (RCW 26.09.090(1)(a)–(f)) are the same checklist the judge works from. + +## Amount and duration + +Washington has **no guideline or formula** for maintenance amounts — unlike child support. The judge sets an amount and a duration that seem just based on the factors above (RCW 26.09.090(1)). In practice: + +- **Shorter marriages** with a spouse who needs retraining may produce maintenance for a limited period — long enough to get education or training (the "time necessary" factor, RCW 26.09.090(1)(b)). +- **Long marriages**, especially where one spouse stayed home for years or has health problems, can produce maintenance of longer duration or without a fixed end date — but courts generally expect maintenance to be limited or at least periodically re-examined; outcomes depend heavily on the facts. +- The standard of living during the marriage matters, but the paying spouse's own needs and obligations are also weighed (RCW 26.09.090(1)(c), (f)). + +## When maintenance ends + +Unless the spouses agree in writing or the decree says otherwise, the obligation to pay future maintenance **ends automatically** when (RCW 26.09.170(2)): + +- Either party dies; or +- The person receiving maintenance remarries or registers a new domestic partnership. + +WashingtonLawHelp.org's *Divorce guide* states the same rule in plain terms: "Spousal support payments generally end when you remarry or die." An agreement or decree can provide otherwise, so read the final order carefully. + +## Agreeing on maintenance: separation contracts + +You and your spouse can agree about maintenance in a written **separation contract**, which may cover maintenance, property, parenting, and child support (RCW 26.09.070(1)). When a divorce case is filed, the contract binds the court unless the court finds it was **unfair at the time it was signed** (RCW 26.09.070(3)). A separation contract can also state that its maintenance terms may not be modified later; without that language, maintenance terms in the decree can be modified like any maintenance order (RCW 26.09.070(7)). If you are considering giving up a right to maintenance by agreement, get legal advice first. + +## Modifying (changing) maintenance later + +A maintenance award can be changed after the divorce, but only in limited ways (RCW 26.09.170(1)): + +- A modification can apply **only to payments that come due after** the request for modification is filed — not to past-due installments (RCW 26.09.170(1)(a)). +- Generally, modification requires a **substantial change of circumstances** since the original order (RCW 26.09.170(1)(b)) — for example, a major change in either spouse's income, health, or needs. +- If the maintenance obligation was made **non-modifiable by agreement** (see previous section), the court will honor that (RCW 26.09.070(7)). +- By contrast, **property division** orders are essentially final and generally cannot be modified at all (RCW 26.09.170(1)). + +## Enforcing a maintenance award + +If your former spouse stops paying, your remedies depend on how the order is set up: + +- **Through the state Support Registry:** If the court order says maintenance payments go through the state Support Registry and you have a child support case open with the Division of Child Support (DCS), DCS can collect maintenance for you, including some back payments (WashingtonLawHelp.org, *Enforce your divorce decree: Money and property issues*). +- **Maintenance only, no child support case:** DCS will not open a case. You can file a **motion for contempt**. If the judge finds your ex-spouse had the ability to pay and did not, the judge can order payment or impose fines; a spouse who proves inability to pay despite good-faith effort generally is not held in contempt (WashingtonLawHelp.org, *Enforce your divorce decree*). +- Money awards in a divorce order are enforceable like other civil judgments — typically for 10 years, with renewal available (WashingtonLawHelp.org, *Enforce your divorce decree*). + +## Practical tips + +- **Ask early.** If you will need support while the case is pending, move for temporary maintenance when you file or respond — use the *Motion for Temporary Family Law Order and Restraining Order* (FL Divorce 223) and file a *Financial Declaration* (FL All Family 131) so the court has your income and expense information (courts.wa.gov, "Court Forms: Divorce (Dissolution)"). +- **Put it in the final order.** Whether you settle or go to trial, make sure the *Final Divorce Order* (FL Divorce 241) states the amount, start date, duration, how payments are made, and what events end maintenance. +- **Document ability to pay.** The paying spouse's ability to pay (RCW 26.09.090(1)(f)) matters; complete financial disclosures truthfully on both sides. +- **Fees can shift.** If the financial situations are lopsided, the court may order one party to help pay the other's attorney fees and costs (RCW 26.09.140). +- **Get advice.** Maintenance outcomes depend heavily on the specific facts. WashingtonLawHelp.org (maintained by Northwest Justice Project) has free guides; the CLEAR legal-aid referral line is 1-888-201-1014 (courts.wa.gov forms page). + +## Sources + +- RCW 26.09.040(3), 26.09.060, 26.09.070, 26.09.090, 26.09.140, 26.09.170 — app.leg.wa.gov (Title 26, Chapter 26.09 RCW) +- WashingtonLawHelp.org (Northwest Justice Project): *Divorce guide* (reviewed 05/07/2026), spousal support section; *Enforce your divorce decree: Money and property issues* (reviewed 03/19/2026) — washingtonlawhelp.org +- Washington State Courts: *Court Forms: Divorce (Dissolution)* — courts.wa.gov/forms/?fa=forms.contribute&formID=13