## Facts

- David Pratt owned a house in Springfield, Virginia, before marrying Morgan Pratt, and the house was titled in David’s name.
- After the marriage, David and Morgan lived in the Springfield house as their home.
- During much of the marriage, Morgan was a homemaker and performed work in and around the house, including cleaning, decorating, and furnishing.
- Morgan also performed or arranged other work connected to the house, including gardening, making drapes, arranging for the bedroom to be painted, and having modifications made to the bedroom ceiling.
- David and Morgan also worked on projects together, including removing wallpaper, painting, and installing drywall.
- Morgan later moved out of the Springfield house, and David filed for divorce.
- In the divorce proceedings, the trial court classified the Springfield house as marital property, relying in part on Morgan’s personal efforts as a homemaker.

## Issues

1. Whether, under Virginia equitable-distribution law, a house acquired before marriage and titled in one spouse’s name may be classified as marital property (rather than separate or hybrid) based on the other spouse’s homemaker services and participation in home-improvement work.
2. Whether the trial court was required to tie any marital interest in the house to a proven increase in value caused by “significant” personal efforts or other marital contributions, rather than treating the entire home as marital.

## Decision

- The Court of Appeals of Virginia held that a premarital, separately titled residence does not become entirely marital property merely because the nonowner spouse performed homemaker services and participated in improvement projects during the marriage.
- The court explained that, at most, such efforts can support a marital interest in any proven increase in the home’s value that is attributable to significant personal efforts or marital contributions, and the trial court must make the findings needed to separate any marital component from the owner-spouse’s separate interest.
- The case was sent back for further proceedings consistent with those requirements.

## Legal Principles

- Property acquired by one spouse before marriage is separate property for purposes of equitable distribution in Virginia.
- Separate property can have a marital component when (and only to the extent that) its value increases during the marriage due to significant personal efforts of either spouse or marital contributions, as addressed in Virginia Code § 20-107.3.
- Homemaker services and household tasks may qualify as “personal efforts” only if the evidence shows those efforts were significant and caused or helped cause a measurable increase in value (as opposed to ordinary upkeep or market-driven change).
- Classification requires proof and findings on causation and valuation: the court must identify the increase in value during the marriage and determine what portion, if any, is linked to personal efforts or other marital contributions.
- A court may not treat the entire premarital asset as marital property absent a legal basis for changing its classification (such as a demonstrated marital share in appreciation or other statutory grounds).

## Conclusion

Pratt v. Pratt addresses how Virginia courts classify a premarital, separately titled home in divorce when the nonowner spouse contributed homemaker labor and participated in improvements: such efforts may support a marital interest only in any proven, causally related appreciation, and the trial court must make findings that distinguish any marital component from the owner-spouse’s separate property.


Pratt v. Pratt, 2011 WL 6412226 (2011)