Marriage of Sullivan

Mark Sullivan (plaintiff) and Janet Sullivan (defendant) married in 1967, and Mark entered medical school in 1968. Janet worked part-time while finishing her own undergraduate degree, then full-time; she left a full-time job to relocate with Mark for his internship, stopped working around their child's 1974 birth, and later worked full-time again through his residency. After Mark completed his training and the couple returned to California, he filed for divorce. The trial court ruled Mark's medical education itself was not a community asset, and Janet appealed. While the appeal was pending, the legislature amended the statutes governing reimbursement for a spouse's contributions to the other's education and their relevance to spousal support.