## Facts

- Husband and wife had a childless marriage lasting about three years.
- Wife filed for dissolution; after a contested trial, the court entered an interlocutory judgment of dissolution.
- The trial court found wife waived spousal support.
- The court found community assets totaled $5,250 and community liabilities totaled $6,450.
- The court awarded wife $3,500 in assets and assigned her $1,000 in community obligations (net +$2,500).
- The court awarded husband $1,750 in assets and assigned him $5,450 in community obligations (net −$3,700).
- Husband appealed only the portion of the interlocutory judgment dividing community assets and obligations.

## Issues

1. Whether the trial court’s allocation of community assets and community obligations complied with Civil Code § 4800’s requirement of equal division of community property.
2. Whether, and in what manner, community debts must be treated as part of “property” when dividing a community estate that is negative or debt-heavy.

## Decision

- The Court of Appeal reversed the property-and-debt division portion of the interlocutory judgment.
- The court held the division was plainly unequal when assets and obligations were considered together.
- The case was remanded for the trial court to effect an equal division consistent with Civil Code § 4800 and applicable court rules.
- The appellate court declined to prescribe a specific method for equalizing a net-negative or debt-heavy estate, leaving implementation to the trial court.

## Legal Principles

- Civil Code § 4800 requires the court to divide community property equally.
- For purposes of dissolution proceedings, “property” includes both community assets and community obligations.
- A division that results in materially unequal net outcomes after accounting for both assets and debts violates the statutory equal-division requirement.
- Trial courts have discretion in the mechanics of allocating debts in difficult, debt-heavy estates, but the end result must satisfy the equal-division mandate.

## Conclusion

The court reversed and remanded because the trial court’s allocation of community assets and debts produced an obviously unequal net distribution, contrary to the statutory requirement that community property—defined to include both assets and obligations—be divided equally.


In re Marriage of Eastis, 47 Cal. App. 3d 459 (Cal. Ct. App. 1975)