Connell v. Francisco
Supreme Court of Washington
898 P.2d 831 (Wash. 1995)
Shannon Connell (plaintiff) met Richard Francisco (defendant) while Connell was a dancer in a show produced by Francisco in Las Vegas, Nevada. At the time, Francisco owned several companies and had a net worth of approximately $1,300,000. Connell and Francisco began a relationship and cohabitated together in Las Vegas. One of Francisco’s companies purchased The Whidbey Inn (the Inn), a bed and breakfast located in the State of Washington. Connell moved to Washington to manage the Inn and received no compensation for nearly two years, during which Connell prepared breakfast, cleaned rooms, took reservations, and paid bills. Francisco joined Connell in Washington shortly afterward. During their time in Washington, Connell and Francisco were viewed by the community as being married. With Francisco’s consent, Connell used Francisco’s last name. Additionally, Francisco gave Connell an engagement ring. Subsequently, Connell and Francisco separated. At the time of the separation, Connell had $10,000 in cash, some jewelry and clothes, a car, and a leased apartment in New York. Francisco’s net worth had increased to approximately $2,400,000, which was attributable in part to the acquisition of several pieces of real property by Francisco’s companies. Connell filed suit against Francisco, seeking an equitable distribution of the property that was acquired during the relationship. The trial court equitably divided the property acquired during the relationship among Connell and Francisco, based on evidence showing that the property would have been community property had Connell and Francisco been married. The trial court further held that the property owned by each party prior to the relationship was not subject to distribution. Francisco appealed. The court of appeals reversed. The Supreme Court of Washington granted certiorari to review.
Rule of Law
Holding and Reasoning (Guy, J.)
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