## Facts

- Elaine Watt and David G. Watt married in 1972 and separated in 1981 after about nine and one-half years; they had no children.
- During the marriage, David was a full-time student progressing to medical school and received his medical degree about five months after separation.
- Elaine worked full-time throughout the marriage and applied her earnings to household and family expenses.
- From 1975–1981 (excluding 1977), the parties’ combined gross income was $81,779.92; Elaine contributed $66,923.92 and David contributed $14,856.
- David obtained student loans totaling $26,642; at least $3,000 paid direct education costs, and the remaining loan proceeds were used largely for the parties’ living expenses.
- In the dissolution proceeding, Elaine sought spousal support and reimbursement to the community for funds used to finance David’s education; David sought to avoid paying Elaine’s attorney fees and costs.

## Issues

1. Whether, in determining spousal support under former Civil Code § 4801, the trial court had to consider the totality of the nonstudent spouse’s contributions to the student spouse’s education, including support for living expenses that enabled the education.
2. Whether the spousal-support analysis improperly relied only on the parties’ actual marital standard of living without considering why that standard was low in a career-threshold marriage.
3. Whether community reimbursement for education under former Civil Code § 4800.3 includes ordinary living expenses incurred while one spouse was in school.
4. Whether the trial court abused its discretion by ordering David to pay Elaine’s attorney fees and costs.

## Decision

- The Court of Appeal affirmed in part and reversed in part.
- It reversed the denial of spousal support and remanded for reconsideration because the trial court failed to consider the totality of Elaine’s contributions to David’s educational attainment, including living-expense support.
- It held the trial court improperly focused on the depressed marital standard of living without accounting for the parties’ choice to accept that standard while investing in David’s education.
- It affirmed the denial of community reimbursement for ordinary living expenses, holding such expenses are generally not reimbursable under § 4800.3.
- It affirmed the order requiring David to pay Elaine’s attorney fees and costs.

## Legal Principles

- In a dissolution involving an education-driven, career-threshold marriage, spousal support under former Civil Code § 4801 must account for the totality of the supporting spouse’s contributions to the other spouse’s attainment of an education, including payment of living expenses that facilitated the education.
- The marital standard-of-living factor must be applied in context; a low standard of living attributable to a mutual decision to finance education cannot be treated as a complete measure of appropriate postseparation support.
- Community reimbursement for education under former Civil Code § 4800.3 generally covers direct educational expenditures and does not ordinarily include routine living expenses, even if those expenses made the education possible.
- Attorney-fee awards in dissolution proceedings are reviewed for abuse of discretion and may be upheld based on relative financial circumstances and equitable allocation of litigation costs.

## Conclusion

The court required a renewed spousal-support determination that weighs the supporting spouse’s full financial role in enabling the other spouse’s education and earning capacity, while limiting statutory community reimbursement for education to direct education-related costs and affirming a fee-shifting order against the newly credentialed spouse.


In re Marriage of Watt, 214 Cal. App. 3d 340 (Cal. Ct. App. 1989)