Williams v. Williams

CLIFFORD, Justice,

dissenting.

Because in my view, the trial court failed to properly credit Richard Williams for an amount approximating the full extent of his nonmarital interest in the Gagnon Road and Elm Street properties in Fairfield, I respectfully dissent.

When land is purchased and buildings are constructed by one party prior to the marriage, absent a conveyance to the spouse that property remains nonmarital throughout the marriage and is not converted to marital property simply by virtue of the marriage. West v. West, 550 A.2d 1132, 1134 (Me.1988). Moreover, the nonmarital estate must be credited with any increase in the value of that nonmarital property during the marriage. Id.; 19 M.R.S.A. § 722-A(2)(E) (1981). Although Richard introduced no expert evidence as to the allocation of the increase in value between the marital and nonmarital portions of the property, the lack of such evidence does not justify the result reached by the court.

The evidence did show that the Gagnon Road property was acquired by Richard pri- or to the marriage, and that he invested $16,000 of his own money in the property. Moreover, the building was substantially complete at the time of the marriage in 1978. The marital contribution to the property consisted only of payments on the mortgage (reduced from the $24,000 borrowed to a balance of $12,450 at the time of the divorce) and some carpentry work by Richard and Lauris during the marriage. The court, however, determined that of the property’s $87,-000 value in 1992, only $16,000, the amount of Richard’s actual cash investment in the property prior to the marriage, was nonmarital. The court credited the marital estate with the entire increase in the value of the land and buildings between 1978 and 1992 and none to Richard’s nonmarital estate despite Richard’s initial investment and ownership. To uphold such a result, this court erroneously applies the presumption of 19 M.R.S.A. § 722-A(3) (1981), that property is marital, *1125to all of the Gagnon Road property. By its terms, however, this presumption applies only to that part of the property acquired, i.e., paid for or improved, subsequent to the marriage. See West, 550 A.2d at 1134 (clear error for trial court to credit husband’s non-marital estate with only twenty-three percent of the value of the property when land was purchased and barn and seventy-five percent of house were constructed by husband prior to marriage).

Although less egregious, the trial court similarly erred in apportioning the apartment buildings located on Elm Street, purchased by Richard nearly two years prior to the marriage, crediting the nonmarital estate with only $11,612, or nine percent of their $125,000 value. See West, 550 A.2d at 1134.

I would vacate the divorce judgment and remand for a redetermination of all economic issues.