## Facts

- Jacklynn Naomi Price (wife) and Harold Price (husband) married in 1969.
- Jacklynn worked as a registered nurse before marriage, left full-time employment after marrying, and later stopped outside work after the birth of the parties’ first child to focus on homemaking and parenting.
- Harold held interests in a closely held family corporation, Unity Stove Company, and a related real-estate holding company, H & SP Realty, Inc.
- Harold received Unity stock as gifts from his father: 25% before the marriage and another 25% during the marriage.
- During the marriage, the value of Harold’s business interests increased substantially.
- Jacklynn’s efforts were primarily as homemaker and parent; she also provided limited assistance connected to the business (e.g., customer contacts on occasions, advertising assistance, and attending conventions).
- In divorce proceedings, the trial court treated part of the appreciation in Harold’s separate-property business interests as marital property and awarded Jacklynn a distributive share.
- Harold appealed, disputing whether homemaker and parenting efforts could qualify as “contributions or efforts” that convert appreciation of separate property into marital property under Domestic Relations Law (DRL) § 236(B).

## Issues

1. Whether DRL § 236(B)(1)(d)(3) treats appreciation in one spouse’s separate property during the marriage as marital property when the appreciation is due in part to the other spouse’s indirect contributions as homemaker and parent.
2. Whether, and to what extent, a court must require a causal connection between the nontitled spouse’s contributions and the appreciation to classify that appreciation as marital property.

## Decision

- The New York Court of Appeals held that appreciation in the value of one spouse’s separate property during the marriage is marital property to the extent it is due in part to the other spouse’s contributions, including indirect contributions as homemaker and parent.
- The court interpreted “contributions or efforts” in DRL § 236(B)(1)(d)(3) to include non-market domestic labor and childrearing.
- The court emphasized that only the portion of appreciation causally attributable to the other spouse’s contributions is marital; any passive or unrelated increase remains separate.
- The court affirmed the classification rule applied to Harold’s business-interest appreciation and upheld equitable distribution of the attributable portion.

## Legal Principles

- DRL § 236(B) broadly defines marital property, while separate property is a limited exception.
- Separate property includes gifts and property acquired before marriage, but “increase in value” of separate property is excluded from separate property to the extent the appreciation is due in part to the other spouse’s contributions or efforts.  
- “Contributions or efforts” under DRL § 236(B)(1)(d)(3) include indirect contributions as homemaker and parent, not only direct work in the asset or business.
- Classification of appreciation requires a causal nexus: the nontitled spouse must show that contributions were a factor in the appreciation; courts must apportion between attributable (marital) and non-attributable (separate) increases.
- Trial courts may resolve valuation and apportionment through fact-finding and equitable distribution determinations.

## Conclusion

The court held that a spouse’s homemaking and parenting efforts can qualify as “contributions or efforts” under DRL § 236(B)(1)(d)(3), making appreciation in the other spouse’s separate property marital to the extent those efforts contributed to the increase in value, with the remainder staying separate.


Price v. Price, 69 N.Y.2d 8, 511 N.Y.S.2d 219 (N.Y. 1986)