Berkman v. Berkman
Mere completion of “course work” and earning of “credits” is not a marital asset to be valued and distributed.
McGowan v. McGowan
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.
Golub v. Golub
Enhancement during marriage of actress’ earning capacity is marital asset, even though there is no license.