Sunkidd Venture, Inc. v. Snyder-Entel

Thompson, J.

(concurring in part, dissenting in part) *218The alleged lease liability in this case clearly is a community debt. The general rule is that upon dissolution of the marriage, the former spouses are individually liable for the former community’s debt, but only as to "property held by either spouse which was formerly the couple’s community property and which is otherwise subject to execution.” Baffin Land Corp. v. Monticello Motor Inn, Inc., 70 Wn.2d 893, 906, 425 P.2d 623 (1967); sec Northern Commercial Co. v. E.J. Hermann Co., 22 Wn. App. 963, 970, 593 P.2d 1332 (1979); see generally Harry M. Cross, The Community Property Law in Washington (Revised 1985), 61 Wash. L. Rev. 13, 144-45 (1986); Washington State Bar Ass’n, Washington Community Property Deskbook § 6.20, at 6-12 (George T. Shields et al. eds., 2d ed. 1989). However, a creditor’s recovery in this circumstance "is limited to the net community equity at the time of dissolution of the marriage.” Cross, supra, at 145; see Watters v. Doud, 95 Wn.2d 835, 838-41, 631 P.2d 369 (1981).

In this case, since the community has been dissolved, the creditor sought to hold Ms. Snyder-Entel liable individually. The creditor hopes to satisfy the judgment against Ms. Snyder-Entel’s individual property that was not a part of the former community’s net equity at the time of the dissolution, such as her current earnings.

As noted in the majority opinion, a former spouse may be liable individually under RCW 26.16.205, the family expense doctrine. Under this statute, a community debt for a family expense may be enforced against the separate property of either spouse, even if that spouse did not individually incur the debt. Rent of the family’s residence is a family expense. Roller v. Blodgett, 74 Wn.2d 878, 880, 447 P.2d 601 (1968); Strom v. Toklas, 78 Wash. 223, 229-30, 138 P. 880 (1914).

In both of the cases relied on by the majority, the lease liability was for dwellings in which the family actually resided. Roller, 74 Wn.2d at 880; Strom, 78 Wash, at 229-30. No cases in Washington have addressed the issue presented in this case: expenses for a dwelling after the family has moved.

*219Lease liability in these circumstances should not be a family expense. After moving from the apartment the En-tel family certainly resided elsewhere; thus, under the majority opinion, the costs of maintaining two dwellings would be family expenses under RCW 26.16.205, even though the family did not actually reside in one of the dwellings during the period at issue. Rental expense for a dwelling in which the family did not reside should not be a family expense.

Here the alleged liability is purely contractual, based on an agreement Ms. Snyder-Entel did not sign. As the creditor points out, both spouses are competent to manage and control the community’s property. RCW 26.16.030. Therefore, the community is liable for the contractual debts incurred by either spouse on behalf of the community. See Huling v. Vaux, 18 Wn. App. 222, 225-26, 566 P.2d 1271 (1977). However, the liability in this circumstance is to the community, not to the individual spouse. Under Watters, the creditor’s judgment should be limited to the former community’s net equity at the time of the dissolution. Watters v. Doud, 95 Wn.2d 835, 841, 631 P.2d 369 (1981).

I agree the case must be remanded, but I would not permit the creditor to obtain a judgment against Ms. Snyder-Entel’s current assets that were not part of the former community’s net equity at the time of the dissolution.

Review denied at 134 Wn.2d 1007 (1998).