Elaine Watt (plaintiff) and David Watt (defendant) were married from 1972–1981. During the entire marriage, Elaine worked full-time, and David was a student, ultimately receiving his medical degree five months after the parties separated. The couple moved to Hawaii in 1974 for David to continue his studies and lived a sparse lifestyle in order to get by on Elaine’s income without incurring additional debt. While the parties’ divorce action was pending, the California legislature amended several provisions of the Family Code affecting spousal reimbursement and spousal support for contributions to the education of the other spouse. The trial court ruled that Elaine had made only a minimal contribution to David’s education and that this contribution did not qualify for consideration as to spousal support. Elaine appealed the trial court’s ruling.