Marriage of Graham
Court of Appeals of California
109 Cal. App. 4th 1321 (2003)
Katherine (defendant) and Jeffrey Graham (plaintiff), married in 1992, saw Jeffrey enroll in law school in 1994 while also working as a Costa Mesa police officer; the couple spent over $12,000 in community funds on Jeffrey's legal education. When Jeffrey filed for divorce in 1999, he had one semester of law school left and didn't plan to take the bar exam; he testified he never intended to become an attorney and attended law school purely to pursue an education, all while earning over $4,400 monthly as a police officer. Katherine sought reimbursement for her community contributions toward Jeffrey's legal education, but the trial court denied her request, finding his legal education didn't substantially enhance his earning capacity; Katherine appealed.
Whether, under state law, a professional degree constitutes enhanced earning capacity.