Analysis:  Fowlkes

Facts: Husband and wife build an addition on wife's separate property using only the separate funds of each party.

Ruling: Wife's separate property remained 100% hers. She resisted placing the property in joint names, and her resistance led to the breakup of the marriage.

Comment of Olivier Long: If the husband had made the same investment of his separate funds in property that was marital and had he been able to trace the money back to a separate account of his, the result might have been different. This case demonstrates the importance of a premarital agreement or consultation with an attorney before investing money in property belonging to someone else!