Stava v. Stava

Summary

The court held that marital funds used to reduce principal on debt encumbering property acquired before marriage create a proportionate marital interest in the property, including a proportionate share of passive appreciation. It adopted the source of funds rule, reversed the classification and division of Lot 14 and the land portion of Lot 15, and remanded for a new equitable-division hearing. It affirmed the determination that the barn and other improvements on Lot 15 were marital property. Justice Cassel, concurring in part and dissenting in part, would leave application of the source of funds rule to the trial court's discretion rather than require a potentially rigid mathematical approach.