Jacklynn N. Price v. Harold Price, 69 N.Y.2d 511 (1986)

CASE: Wife of the owner of a stove company and real estate challenges finding that her contributions as a homemaker did not contribute to the increase in value of the defendant's separate property.

FACTS: Parties were married in 1969; husband received in separte gifts, control of the family business, Unity Stove Company. He was also owner of a corporation which holds title to the real estate holdings of Unity. The defendant gave up her job as a registered nurse after the marriage and worked for Unity and as a private duty nurse for a time. She then gave this up in order to raise the couple's two children, hosting business-related social events for her husband and attending conventions with him from time to time. The Supreme Court found that the defendant's interests in Unity and the related company cosntituted "separate property" since the husband had acquired them as gifts and that whatever direct contributions the wife may have made to Unity were "minimal and inconsequential" and that her direct contributions were "likewise insignificant". Wife appealed this finding; Appellate Division determined that the wife's contributions did warrant an award of the percentage of the appreciation of defendant's separate holdings in Unity and the separate company and remanded to the Supreme Court to determine judgment; Supreme Court granted husband's stay to appeal the question of whether she was entitled to anything to the Court of Appeals.

QUESTION: Whether a nontitled spouse's "contributions or efforts" as homemaker and parent are entitled to recognition by the court in awarding said spouse a share of the appreciated value of the titled spouse's separate property which occurred during the parties marriage?

DEFENDANT ARGUES: The contributions of the homemaker spouse have already been taken into account in other provisions of state law, namely in determining the equitable distribution of marital property and in fixing the amount and duration of maintenance. Therefore, the legislature did not intend that a court should consider such contributions in determining whether an appreciation in separate property should be treated as marital property.

COURT SAYS: Affirms the Appellate Division, finds for the wife.

HOLDING: Under the Equitable Distribution Law an increase in the value of separate property of one spouse, occurring during the marriage and prior to the commencement of matrimonial proceedings, which is due in part to the indirect contributions or efforts of the other spouse as homemaker and parent, should be added to the sum of marital property for equitable distribution.

RATIONALE:

• As a general rule, however, where the appreciation is not due, in any part, to the efforts of the titled spouse but to the efforts of others or to unrelated factors including inflation or other market forces, as in the case of a mutual fund, an investment in unimprovished land, or in a work of art, the appreciation remains separate property, and the nontitled spouse has no claim to a share of the appreciation.
• The term "marital property" should be construed broadly and "separate property" should be construed narrowly.

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