Hoak v. Hoak
Professional degrees are not property, but reimbursement or alimony may be given.
Professional degrees are not property, but reimbursement or alimony may be given.
Husband-wife privilege applies only to confidential communications, not to observations that could have been made by a third party.
Medical degree is not an asset for purposes of an unjust enrichment claim.
Spouse who supports education of partner is entitled to share of increased earnings. Trial court has discretion to choose among several different approaches.
Court should consider maintenance as compensation for supporting spouse getting professional degree.
(1) Award of maintenance was proper to compensate spouse for support to get professional degree. (2) Maintenance does not have to be based solely on need.
Educational degree not a marital asset. Note: This case was under the old statute and was essentially overruled by Lundberg.
Professional degrees are not property, but reimbursement or alimony may be given.
Professional degrees are not property, but reimbursement or alimony may be given.
Nurse’s anesthesiology certificate is marital asset.
Professional degrees are not property, but reimbursement or alimony may be given.
Professional degrees are not property, but reimbursement or alimony may be given.
Nurse’s anesthesiology certificate is marital asset.
Professional degree is not marital property.
Professional degrees are not property, but reimbursement or alimony may be given.
Valuation of established practice subsumes any value of medical license.
Value of law practice includes enhanced earning capacity. Professional degree or license merges with the professional practice itself where the practice has been ongoing for a number of years during the marriage.
Mere completion of “course work” and earning of “credits” is not a marital asset to be valued and distributed.
Wife’s master’s degree was marital property, as an academic degree should be treated the same as a professional license. However, a teaching certificate was not marital property because although it was awarded after the marriage, she had completed all the requirement before the marriage.
Enhancement during marriage of actress’ earning capacity is marital asset, even though there is no license.