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Marriage of Watt | 262 Cal. Rptr. 783 (1989)

As adult students, we regularly encounter marriages in which one spouse works, providing a far greater share of the living expenses, while the other attends school full time. Known as career threshold marriages, these unions can present unique considerations for courts in divorce proceedings. The 1989 California case of Marriage of Watt explores one such scenario.

Elaine and David Watt were married in 1972. They had no children. During their 9 and a half year marriage, Elaine worked full time while David was a full time student. In this time, David obtained his undergraduate and graduate degrees and started medical school.

Elaine’s income covered most of the couple’s living expenses. David’s student loans covered his educational expenses and the couple’s remaining living expenses. With only one working spouse, the couple was committed to temporarily maintaining a frugal lifestyle to avoid additional debt.

5 months before David got his medical degree, the couple separated. Elaine started working two part time jobs and had trouble meeting living expenses for a while. She became interested in going back to school, which she attempted briefly while also working, but found the arrangement untenable.

David began work as a practicing anesthesiologist, making good money.

The Watts subsequently divorced, and the court retained jurisdiction over the disputed matters.

Specifically, the trial court denied Elaine’s request for spousal support, relying heavily on the couple’s low standard of living while married. It also denied her reimbursement of community funds spent on David’s education, finding that her contributions thereto were minimal and not to be considered. Elaine appealed.

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