IN RE the MARRIAGE OF Jack Allen BLAINE, and Qing He

480 P.3d 691
CourtSupreme Court of Colorado
DecidedFebruary 16, 2021
DocketSupreme Court Case No. 19SC967
StatusPublished
Cited by2 cases

This text of 480 P.3d 691 (IN RE the MARRIAGE OF Jack Allen BLAINE, and Qing He) is published on Counsel Stack Legal Research, covering Supreme Court of Colorado primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
IN RE the MARRIAGE OF Jack Allen BLAINE, and Qing He, 480 P.3d 691 (Colo. 2021).

Opinion

Attorneys for Petitioner: Law Offices of Rodger C. Daley Rodger C. Daley Dorian Geisler Denver, Colorado

Attorneys for Respondent: GreenLaw International LLC Ralph J. Strebel Highlands Ranch, Colorado

Aitken Law, LLC Sharlene Aitken Denver, Colorado

Attorneys for Amicus Curiae Colorado Chapter of the American Academy of Matrimonial Lawyers: Lass Moses Ramp & Cooper LLC Patricia A. Cooper Marie Avery Moses Denver, Colorado

En Banc

JUSTICE SAMOUR delivered the Opinion of the Court.

¶1 We agreed to review this marriage dissolution case to determine whether a spouse's conveyance of his interest in a home through an interspousal transfer deed ("ITD") automatically overcomes the presumption of marital property in the Uniform Dissolution of Marriage Act, §§ 14-10-101 to - 133, C.R.S. (2020) ("UDMA"), provided that there is proof that the conveying spouse intended to exclude the property from the marital estate. We conclude that it does not.

¶2 Under the UDMA, "marital property" is subject to equitable division in a marriage dissolution proceeding. § 14-10-113(1), C.R.S. (2020). The UDMA creates a "presumption of marital property" with respect to "all property acquired by either spouse subsequent to the marriage and prior to a decree of legal separation." § 14-10-113(3). But this presumption "is overcome by a showing that the property was acquired by a method listed" in one of four statutory exceptions. Id. (referring to exceptions (a) through (d) in section 14-10-113(2) ). The court of appeals correctly acknowledged that the ITD executed in this case did not fall within the statutory exception that allows couples to exclude property from the marital estate through a "valid agreement." § 14-10-113(2)(d). Yet, without the benefit of findings in the record as to whether any of the other exceptions applied, and without itself exploring those exceptions, the court of appeals concluded that the ITD was an effective means of conveying, as separate property, a spouse's interest in a home acquired during the marriage, given that there was evidence of the conveying spouse's intent to exclude the property from the marital estate.

¶3 We now hold that a party may overcome the marital property presumption in the UDMA only through the four statutory exceptions set forth in section 14-10-113(2). Because the court of appeals improperly created a new exception to the presumption, we reverse its judgment and remand for further proceedings consistent with this opinion.

I. Facts and Procedural History

¶4 In September 2015, Jack Allen Blaine

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Cite This Page — Counsel Stack

Bluebook (online)
480 P.3d 691, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-the-marriage-of-jack-allen-blaine-and-qing-he-colo-2021.