Craft v. Craft

914 So. 2d 648 (2005)

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Craft v. Craft

Louisiana Court of Appeal
914 So. 2d 648 (2005)

  • Written by Liz Nakamura, JD

Facts

Alfred Craft (defendant) was the sole proprietor of Bo Construction and Dirt Co., Inc. (BCD), a construction and dirt-work business. A few years after starting BCD, Alfred married Connie Craft (plaintiff). Twenty-seven months later, Connie petitioned for divorce and, in relevant part, sought reimbursement for the increase in value of BCD during the marriage. Connie argued that she was entitled to reimbursement because the community was undercompensated for Alfred’s labor. Financial evidence presented during trial indicated that during the 27-month marriage, BCD earned gross receipts of approximately $550,000, Alfred paid down approximately $100,000 in business debt, and Alfred received an annual salary of less than $20,000 despite handling most of BCD’s work himself. Based on the evidence presented, the trial court determined that BCD increased in value by approximately $7,000 during the marriage. The trial court awarded Connie $3,500 as her one-half share of BCD’s increase in value, holding that the increase was attributable to Alfred’s undercompensated labor. Alfred appealed.

Rule of Law

Issue

Holding and Reasoning (Caraway, J.)

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