Innerbichler v. Innerbichler
Court of Special Appeals of Maryland
752 A.2d 291 (Md. Ct. Spec. App. 2000)
Nicholas Innerbichler (plaintiff) co-founded and owned 51% of a government contracting company before marrying Carole (defendant); the company was still small when they married but grew from $188,000 to $51 million in annual revenue over the marriage after receiving a key SBA certification just three months post-wedding, growth the trial court attributed primarily to Nicholas's active work during the marriage. In the divorce, the circuit court treated the appreciation in Nicholas's company interest as marital property and awarded Carole roughly half of that appreciation's value, over $2 million; Nicholas appealed.
Whether property that is initially non-marital can become marital property if increases in its value result primarily from the active efforts of the owner-spouse during the marriage.