## Facts

- Before marrying W. J. Sorrells in 1884, C. V. Sorrells owned two mules as her separate property; they were then colts worth about $35 each.
- After marriage, the husband managed and cared for the mules, and the marital community furnished their feed.
- By 1888, the same two mules had increased in market value to about $75 each due to growth and maturation.
- W. M. Stringfellow held a judgment against the husband and caused execution to be levied on the mules to satisfy the debt.
- The wife filed a statutory proceeding to try the right of property, replevied the mules, and claimed they remained her separate property, including the increased value.

## Issues

1. Whether the increased market value of a पत्नी’s premarital livestock—attributed to growth and community-funded maintenance—becomes community property subject to execution for the husband’s debt.
2. Whether “increase” of separate livestock means mere appreciation in value or instead refers only to progeny/offspring.

## Decision

- The Supreme Court of Texas affirmed judgment for the wife.
- The court held the mules were the identical animals owned by the wife before marriage and remained her separate property.
- The mules’ increased market value from growth and care did not convert any part of them into community property.
- Because the property remained separate, it was not subject to execution to satisfy the husband’s debt.

## Legal Principles

- For separate livestock, “increase” refers to progeny or descendants of the original stock, not appreciation in the value of the same animals.
- Mere enhancement in value of separate personal property through maturation, growth, or ordinary care does not change the property’s separate character.
- Precedents concerning “increase” of a wife’s separate land do not justify recharacterizing separate livestock in a manner that would diminish the spouse’s separate estate.

## Conclusion

The court concluded that a wife’s premarital livestock remains her separate property despite post-marital growth and increased market value, even where community resources contributed to maintenance, and therefore the animals cannot be reached by the husband’s creditor through execution.


Stringfellow v. Sorrells, 18 S.W. 689 (Tex. 1891)