Marriage of Martin
Supreme Court of Arizona
752 P.2d 1026 (1986)
Richard Martin (plaintiff) and Mary Martin (defendant) married in 1959 and traveled extensively during the marriage. In 1979 they moved to California, but Mary then moved alone into a retirement community in Prescott, Arizona while Richard continued to support her from afar. Before Richard ever relocated to Arizona, Mary filed for divorce there in 1982. Richard argued California law should govern the character of his post-separation income, which would make it his separate property; Arizona's trial court instead applied Arizona law and treated that income as community property. Richard appealed.
Whether a state with personal jurisdiction over a divorce action may apply its own substantive law to determine the community or individual character of property acquired by a spouse who was never domiciled in that state.