Marriage of Valli

Frankie Valli, while married to Randy Valli, bought a $3.75 million life insurance policy using community funds and named Randy as the sole beneficiary. After the couple separated, Randy argued in the dissolution proceeding that the policy was her separate property because the purchase was a transaction between Frankie and the insurance company, a third party, rather than an interspousal transaction, so the transmutation statutes' writing requirement did not apply. The trial court held the policy was community property, reasoning Frankie never relinquished his community interest in writing. The court of appeal reversed, agreeing the transmutation statutes were limited to interspousal transactions. Frankie appealed.