Estate of Bray
Court of Appeal of California
40 Cal. Rptr. 750 (1964)
Walter Bray ran a business his son Dick (defendant) worked in for over two decades; starting in 1944, Walter secretly funded a joint-tenancy savings account and jointly held savings bonds with Dick, depositing business funds annually, with Dick unaware of the balances or even the bonds' existence until Walter's death in 1960. Walter's wife Belle (plaintiff) never knew of either account. Trial evidence showed Walter wanted Dick to have the funds because of his valuable work for the business but deliberately kept Dick unaware until Walter's death; the probate court found this was a transfer for valuable consideration (Dick's services) and awarded Dick the full value, and Belle appealed, claiming her statutory one-half interest.
Whether transfers of community property by a husband, made in recognition of valuable services provided by an employee, are voidable by the wife under state law.