Holman v. Holman
Missouri Court of Appeals
228 S.W.3d 628 (Mo. Ct. App. 2007)
William owned a farmhouse worth $54,640 before marrying LaVonne, and the couple later jointly spent $90,000 remodeling it, bringing its value to $185,000 by trial; William separately acquired commercial land worth $30,000 as nonmarital property from his father, and the couple jointly spent $75,000 building a commercial structure on it, bringing that property's value to $127,000 by trial. In dividing the properties, the trial court simply subtracted William's original nonmarital contribution from each property's current value and split the remaining increase evenly between the spouses, rather than applying a proportional formula; William appealed.
Whether a spouse who contributes nonmarital property toward acquiring additional property is entitled to a share of that acquired property in the ratio of the nonmarital investment to the total nonmarital and marital investment in it.