In Re the Marriage of Jack Allen Blaine, and Qing He

Summary

The court held that an interspousal transfer deed does not, by itself, overcome the Uniform Dissolution of Marriage Act's presumption that property acquired during marriage is marital property. That presumption may be overcome only through one of the four statutory exceptions, and the deed's accompanying evidence of intent to exclude the property is not an additional exception. The court reversed and remanded for findings on whether any of the statutory exceptions applied.