Karen and Jess Martinez married in 1968. At the time, both had high school educations. The Martinezes had three children between 1970 and 1975. Beginning in 1970, Jess completed the requirements for a bachelor’s degree, and then decided to attend medical school. He was in medical school from 1977 until 1981, and financed his education without assistance from his wife. Later, the couple filed for divorce. At issue was how to equitably divide the couple’s property. On appeal, the intermediate appellate court instructed the trial court to devise an award of equitable restitution to Karen in compensation for her intangible contributions to the marriage that helped Jess to obtain his medical degree. The case was then appealed to the state supreme court.