Fields v. Michael
Court of Appeal of California
205 P.2d 402 (1949)
Mrs. Fields (plaintiff) was married to W.C. Fields from 1900 until his death in 1946; all of his assets from that period were community property. Though he deserted her years into the marriage and never told her about his finances, they remained legally married. During his life, Mr. Fields gave away roughly $482,450 to sixteen recipients without Mrs. Fields's knowledge or consent. After his death, with most of the gift recipients having spent the money or disappeared, Mrs. Fields sued Ms. Michael (defendant), the estate's executrix, for her one-half share ($241,225) of those unauthorized lifetime gifts, since the estate was the only remaining source of recovery.
Whether a wife may bring an action against her husband's estate to recover her one-half interest in the value of an unauthorized gift of community property made by the husband during his lifetime.