## Facts

- Alfred Craft operated Bo Construction and Dirt Co., Inc. (BCD), a construction and dirt-work business, as his separate property because he started it before marrying Connie Craft.
- Connie and Alfred married a few years after Alfred began BCD.
- After a 27-month marriage, Connie petitioned for divorce and sought reimbursement connected to BCD’s increase in value during the marriage.
- Connie claimed the community was undercompensated for Alfred’s labor because, while married, Alfred handled most of the work for BCD but paid himself an annual salary of less than $20,000.
- Financial evidence at trial showed that during the marriage BCD had gross receipts of about $550,000 and paid down roughly $100,000 in business debt.
- The trial court found that BCD increased in value by approximately $7,000 during the marriage.
- The trial court awarded Connie $3,500, representing one-half of the $7,000 increase, reasoning that the increase in value was attributable to Alfred’s undercompensated labor performed during the community.
- Alfred appealed the reimbursement award.

## Issues

1. Whether a spouse is entitled to reimbursement for one-half of the increase in value of the other spouse’s separate business during the marriage when the increase is attributed to the owner-spouse’s undercompensated labor during the community.

## Decision

- The court of appeal upheld the trial court’s determination that BCD’s value increased by about $7,000 during the marriage.
- The court of appeal upheld the finding that the increase in BCD’s value was attributable to Alfred’s undercompensated labor during the community, given the evidence of substantial gross receipts and debt reduction alongside Alfred’s comparatively low salary.
- The court of appeal affirmed the award to Connie of $3,500, representing one-half of the proven increase in value of Alfred’s separate business during the marriage.

## Legal Principles

- A spouse’s business owned before marriage remains separate property, but value growth during the community can support a reimbursement claim when the growth is caused by community labor rather than passive factors.
- When the owner-spouse’s labor during the community is not fairly compensated as community income and the separate business retains the benefit, the community may recover the value increase attributable to that underpayment.
- The amount of any reimbursement tied to a separate business depends on proof of both (1) an increase in value during the community and (2) a link between that increase and community labor.
- On appeal, valuation and causation findings in this setting are treated primarily as factual determinations and are reviewed with deference to the trial court when supported by the record.

## Conclusion

Craft v. Craft holds that, in a divorce-related reimbursement dispute, a spouse may recover one-half of the proven increase in value of the other spouse’s separate business when the increase is supported by evidence and is found to result from the owner-spouse’s underpaid labor during the community; the appellate court affirmed the $3,500 award based on a $7,000 increase in the value of BCD during the 27-month marriage.


Craft v. Craft, 914 So. 2d 648 (2005)