Marriage of Watt
Court of Appeal of California
262 Cal. Rptr. 783 (1989)
Elaine Watt (plaintiff) and David Watt (defendant) were married from 1972 to 1981. Throughout the marriage Elaine worked full-time while David was a student, earning his medical degree just five months after the couple separated. The Watts moved to Hawaii in 1974 so David could continue his studies, living frugally on Elaine's income alone to avoid taking on more debt. While the divorce was pending, the California legislature amended the Family Code provisions governing both spousal reimbursement and spousal support for contributions to a spouse's education. The trial court found that Elaine's contribution to David's education was only minimal and did not count toward spousal support. Elaine appealed.
Whether a working spouse's contributions to the community's living expenses, made while the other spouse obtains an education, may be considered only in setting spousal support and not as a basis for reimbursement.