Terms, Dates and Concepts

Click on the term below for a Family Law definition as well as (where applicable) cross-references to the pertinent cases and dates.

Alienation of affections
Common-law marriage
Community property
Dates to remember
Dual property states
Due Process Clause
Equal Protection Clause
Equitable distribution
Heartbalm Statute
Holding
Hotchpot states
Inception of title
Inter-spousal immunity
Loss of consortium
Marital imunity See "Inter-spousal immunity"
"NoCaL" states
"Sand castle factor"
Source of funds theory
Transmutation of property theory
"WAANC" states
"WILT" states


Alienation of affections

(From Black's): A tort claim for willful or malicious interference with a marriage by a third party without justification or excuse. This tort is recognized in only nine states (as of October 1999).

See Also Heartbalm statutes

States (plus D.C.) which have statutorially abolished alienation of affection:

  1. Alamaba
  2. Arizona
  3. Arkansas
  4. California
  5. Colorado
  6. Connecticut
  7. Delaware
  8. District of Columbia
  9. Florida
  10. Georgia
  11. Indiana
  12. Kansas
  13. Maine
  14. Maryland
  15. Massachusetts
  16. Michigan
  17. Minnesota
  18. Montana
  19. Nebraska
  20. Nevada
  21. New Jersey
  22. New York
  23. North Dakota
  24. Oklahoma
  25. Oregon
  26. Pennsylvania
  27. Rhode Island
  28. Tennessee
  29. Texas
  30. Vermont
  31. Virginia
  32. West Virginia
  33. Wisconsin
  34. Wyoming

States which have judicially abolished alienation of affection:

  1. Idaho (1986)
  2. Iowa (1981)
  3. Kentucky (1992)
  4. South Carolina (1992)
  5. Washington (1980)

States in which alienation of affection is a viable cause of action:

  1. Hawaii
  2. Illinois
  3. Mississippi
  4. Missouri
  5. New Hampshire
  6. New Mexico
  7. North Carolina
  8. South Dakota
  9. Utah

Ohio does not permit monetary recovery for alientation of affection (by statute), Louisiana never recognized it as a cause of action and Alaska does not have case law or statutes which clearly address the issue.

CASE: Funderman v. Mickelson
DATE: Thursday, October 14


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Common-law marriage

(From Black's): A marriage that takes legal effect, without license or ceremony, when a couple live together as husband and wife, intend to be married, and hold themselves out to others as a married couple. The traditional common-law rule was that agreement to marry was the critical element in establishing common-law marriage. Recently, more states have incorporated the cohabitation and repute requirements into the notion of common-law marriage. Common-law marriage is recognized in all states, but can be entered into in only 11 states:

  • Alabama
  • Colorado
  • Iowa
  • Kansas
  • Montana
  • Oklahoma
  • Pennsylvania
  • Rhode Island
  • South Carolina
  • Texas
  • Utah

CASE: In re Estate of Harold L. Garges
DATE: Thursday, October 7; Monday, October 11


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Community property

(From Black's): Property owned in common by husband and wife as a result of its having been acquired during the marriage by means other than gift or inheritance, each spouse holding a one-half interest in the property. The nine community property states are:

  • Arizona
  • California
  • Idaho
  • Louisiana
  • Nevada
  • New Mexico
  • Texas
  • Washington
  • Wisconsin

CASE: Michelle Marvin v. Lee Marvin; Dennis G. Whorton v. Benjamin F. Dillingham; Connell v. Francisco, 127 Wash.2d 339 (1995)
DATE: Thursday, October 14


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Dates to remember

1753 — Lord Hardwick's Act passed, abolishing common-law marriages in England (discussed on Monday, October 11).
1791 — Ratification of the Bill of Rights.
1776 — Date named in Washington's reception statute, which adopted as the law of Washington the law of England as it existed in 1776, unless later superceded by Washington staute.
1791 — Ratification of the Bill of Rights.
1837-1901 — Reign of Queen Victoria; era of substantial changes in family law, including the first married women's property act (1883), passage of the bill authorizing absolute judicial divorce (1858), the first English custody statute granting chancellors the discretion to award custody of children younger than 7 to non-adulterous wives upon divorce et mensa thoro (1839). Her reign was characterized by an attack on the patriarchal family in which men had substantial power.
1839 — Year of passage of the first English custody statute granting chancellors the discretion to award custody of children younger than 7 to non-adulterous wives upon divorce et mensa thoro (husbands retained custody after the child reached the age of 7).
1858 — Judicial divorce authorized in England (discussed on Thursday, October 14); Ecclesiastical courts abolished in England.
1868 — Fourteenth Amendment ratified.
1883 — First married women's property act passed in England.
1964 — Civil Rights Act signed into law by President Johnson.
1967: — New York expanded grounds for divorce beyond adultery.
1970: — California adopts the ground of irreconcilable differences as a ground for divorce.
1969 — Effective year of law making stepparents liable for support of stepchildren in Washington (promting Washington Statewide Organization of Stepparents v. Smith, discussed on Tuesday, October 12).
1970 — Washington Legislature reduces the age of consent to marry for men from 21 to 18 (same as it was for women).
1971Reed v. Reed decided (the first time the Supreme Court struck down a sex classification based on the Equal Protection Clause).
1972 — Washington community property law amended to take away management power from husbands.
1973 — No-fault divorce authorized in Washington; Washington, following the Uniform Marriage and Divorce Act, adopts the ground of irremedial breakdown as the exclusive grounds for divorce.
1996 — Defense of Marriage Act, authorizing states to pass laws declaring that they will not recognized same-sex marriages conducted lawfully in other states, signed into law by President Clinton.
1998 — Washington amends marriage statute to declare marriage a civil contract between a man and a woman, and declaring that same-sex marriages conducted lawfully in other states will not be valid in Washington.


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Dual property states

The 34 states in which only certain assets acquired during marriage are subject to division on divorce. All community property states except Washington fall into this category, limiting assets divisible on divorce to community property (and also quasi-community property as well). See also hotchpot states.


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Due Process Clause

"...[N]or shall any State deprive any person of life, liberty, or property, without due process of law ..." U.S. Const. amend. XIV Sec. 1.

Principle behind the Due Process Clause: The state must treat presons fairly.

OVERVIEW OF THE DUE PROCESS CLAUSE: The Due Process Clause includes both procedural and substantive aspects. On the procedural side, it effects civil and criminal law in different ways. In civil law, procedural due process means the right to not be dragged into a foreign jurisdiction to be sued, the opportunity to be heard, the right to be put on notice when sued (inter alia). In criminal law, procedural due process means the state has the burden of proving a criminal defendant guilty beyond a reasonable doubt, the right to a speedy trial, etc. The Supreme Court ruled, in In re Winship, that the rights of the Bill of Rights are due process requirements, as well as others (as detailed later).

The question of whether due process includes substantive law as well as procedural is the subject of a 500-year debate. Where the idea of equal protection is a more American notion, the idea due process is much older. Substantive due process means that the government may not infringe upon fundamental liberties absent a compelling interest. A woman's right to choose to have an abortion is considered a fundamental right, as an extension of the right to privacy (considered implicit in the Fourteenth Amendment's guarantee of "liberty").

HISTORY: The idea of finding fundamental rights (like the right to privacy) not explicitly ennumerated in the Bill of Rights fell out of vogue with the Roosevelt appointments to the Supreme Court. Before these appointees joined the Court, the Court had blocked many key New Deal programs aimed at regulating the economy on the theory that they violated substantive due process. The minimum wage, for example, was considered a violation of the right to contract. Substantive due process was dusted off for Roe v. Wade, in which the Court found that outlawing abortion violated a woman's right to privacy and, therefore, substantive due process.

CASES: Carey v. Population Services International; Planned Parenthood v. Casey; Bowers v. Hardwick; Littlejohn v. Rose; Cruzan v. Director, Missouri Dept. of Health; DeShaney v. Winnebago County Dept. of Social Services; Walker v. Superior Court; Village of Belle Terre v. Boraas; Moore v. City of East Cleveland; Loving v. Virginia; Zablocki v. Redhail; Baker v. Nelson
DATES: Tuesday, September 28; Wednesday, September 29; Thursday, September 30


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Equal Protection Clause

"No State shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States; nor shall any State deprive any person of life, liberty, or property, without due process of law; nor deny any person within its jurisdiction the equal protection of the laws. U.S. Cont. amend XIV § 1

  1. Deals with classifications created by a statute (men/women, husbands/wives, minors/adults); nearly every statute creates a classification.
  2. Pertains only to state action (federal action is governed by the due process clause of the Fifth Amendment per Bolling v. Sharpe, 347 U.S. 497 (1954)).
  3. Legislative classifications are presumed to be valid, but are analyzed through three levels of scrutiny (depending upon the nature of the classification):
    1. Rational basis: Classification struck down if not rationally related to a legitimate state interest.
      WHEN EMPLOYED: Classifications that do not involve a fundamental right BURDEN OF PROOF: On the litigant attacking the classification.
    2. Intermediate scrutiny: Classification is presumed void unless the government proves that it is substantially related to an important state interest.
      WHEN EMPLOYED: Classifications by sex (Orr) or illegitimacy (Cherlyn Clark v. Gene Jeter).
      BURDEN OF PROOF: On the litigant seeking to defend the classification.
    3. Strict scrutiny: Classifications are presumed void unless the government proves that it is necessary to achieve a compelling state interest.
      WHEN EMPLOYED: Classifications based on race, national origin, alienage or fundamental rights.
      BURDEN OF PROOF: On the litigant seeking to defend the classification.

CASES: William H. Orr v. Lillian M. Orr;Michael M. v. Superior Court; Richard Loving v. Virginia; Zablocki v. Redhail; Baker v. Nelson; Washington Statewide Association of Stepparents v. Smith
DATES: Monday, September 27


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Equitable distribution

(From Black's): The (sometime presumptively equal) division, after divorce, of property accumulated by the spouses during marriage. Black's (Pocket Edition, 1996) says 40 states follow equitable distribution, but Hardisty said on Wednesday, November 17 that equitable distribution is followed in 47 states. The three remaining provide for equal distribution, the so-called "NoCaL" states: New Mexico, California and Louisiana.

See Also "NoCaL" states

DATES: Wednesday, November 17


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Heartbalm Statute

(From Black's): A state law that abolishes the rights of action for alienation of affections, breach of promise to marry, criminal conversation, and seduction of a person over the legal age of consent. About half the states have passed these statutes (Westfall 187).

CASES: Wightman v. Coates; L.L. Standard v. Bolin; Funderman v. Mickelson (case brief lists the nine states in which alienation of affection is still a valid cause of action); Barbara A. v. John G.; Stephen K. v. Roni L.; Kathleen K. v. Robert B.
DATES: Thursday, October 14


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Holding

Best stated as a rule in the following form: rule + facts = conclusion. Put another way, the syllogism: major premise (Humans are mortal) + minor premise (Socrates is human) = Application (Socrates is mortal). Holdings should not be stated too broadly so as to pen in a court when it confronts the same question with slightly different facts (thereby refining the rule), and should be speciic enough to distinguish the case and to provide guidance to lawyers and judges in the future when confronted with similar questions.


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Hotchpot states

The 16 states in which all property of either spouse is subject to distribution on divorce, in the discretion of the court; includes Washington. See also dual property states.

The 16 hotchpot states are:

  1. Alaska
  2. Delaware
  3. Hawai'i
  4. Kansas
  5. Massachusetts
  6. Michigan
  7. Mississippi
  8. Montana
  9. New Hampshire
  10. North Dakota
  11. Oregon
  12. South Dakota
  13. Utah
  14. Vermont
  15. Washington
  16. Wyoming


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Inception of title theory

In distribution of property upon dissolution, the theory that the status of property as separate or community is fixed as of the time it is acquired. The status of the title, as belonging to one estate or the other, is determined by the status of the original right, subsequently matured into full title. Under this rule, property to which one spouse has acquired an equitable right before marriage is separate property, though such right is not perfected until after marriage. Most community property states which follow this formula provide for the community to be compensated for the increase in value attributable to community labor less the amount of natural increase in the value of the separate property.

CASE: Sylvester E. Harper v. Amaryllis Harper
DATE: Friday, November 12


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Inter-spousal immunity

(From Black's): Immunity of one spouse from a tort action by the other spouse for personal injury; this immunity has been abolished in most states. On page 240, Westfall quotes a commentator who notes that, as of 1989, 39 states had totally eliminated the doctrine of inter-spousal immunity and 8 others had partially abolished it. As a result, inter-spousal tort suits are becoming increasingly common, both in ongoing marriages and in connection with divorce.

CASES: Mary B. Mims v. Robert F. Mims; Lesa R. Davis v. John Bostick; William E. Twyman v. Sheila K. Twyman; People v. Mario Liberta; Mary A. Rodriguez v. Bethlehem Steel Corporation; Theodore P. Funderman v. Gordon Mickelson; Deborah S. Brotherton v. Frank P. Cleveland
DATES: Tuesday, October 12; Wednesday, October 13 Thursday, October 14


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Loss of consortium

(From Black's): A loss of the interests that one spouse is entitled to receive from the other, including companionship, cooperation, affection, aid, and sexual relations; such a loss can be recoverable as damages in a personal-injury or wrongful-death action.

CASES: Rodriguez v. Bethlehem Steel Corp
DATES: Thursday, October 14


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"NoCaL" states

Community property states which mandate equal distribution rather than equitable distribution (the system followed in the remaining 47 states) in the distribution of property after dissolution of marriage. In these states, each spouse in a marriage gets half the community property, as opposed to the other states in which the judge is given the discretion to divide the community estate equitably based on a number of factors. Some states follow a rebuttable presumption of equal distribution.

NoCaL states:

  • New Mexico
  • California
  • Louisiana

See Also Equitable distribution

DATES: Monday, November 8; Tuesday, November 9

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"Sand castle factor"

A Hardisty invention; the notion, as applied to the law, that judges love to build sand castles but take even greater glee in kicking them down, especially sand castles constructed by others. This can be applied to any case in which activist judges seem to make rulings counter to the rule of law while insisting that they are not changing anything that much.

DATES: Thursday, November 18


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Source of funds theory

In distribution of property upon dissolution, the theory that when real property is paid for in part before marriage from a spouse's separate funds and in part during marriage from community funds, and improvements are placed on the real property during marriage, such property and its improvements are characterized as part separate and part community property. The community is not reimbursed, but has an actual interest in the property, a "pro tanto community property interest" in such property and improvements in the ratio of the community investment to the total separate and community investment in the property. Under this rule, the community is entitled to the normal appreciation of the property in addition to the appreciation attributable to the labor of the community.

CASES: Marriage of Lydie D. and David E. Moore; Sylvester R. Harper v. Amaryllis M. Harper
DATES: Friday, November 12


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Transmutation of property theory

In distribution of property upon dissolution, the theory that there exists a rebuttable presumption that the constributors of marital property to nonmarital property intended that the commingled property be treated as marital; the failure of a nonmarital property holder to segregate that property will give rise to the rebuttable presumption that the nonmarital property has been transmuted, regardless of the status of title.

CASES: Sylvester R. Harper v. Amaryllis M. Harper
DATES: Friday, November 12


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"WANNC" states

Community property states in which income generated during the marriage from the separate property of one spouse is considered separate property for the purposes of distribution of community property on dissolution of marriage.

"WANNC" states:

  • Washington
  • Arizona
  • Nevada
  • New Mexico
  • California

DATES: Monday, November 8; Tuesday, November 9


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"WILT" states

Community property states and Wisconsin (the nation's only Uniform Marital Property Act state) in which income from the separate property of one spouse generated during marriage is considered community property for the purposes of distribution upon dissolution of marriage.

"WILT" states:

  • Wisconsin
  • Idaho
  • Louisiana
  • Texas


DATES:
Monday, November 8; Tuesday, November 9


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