Marriage of Ogden CA5

CourtCalifornia Court of Appeal
DecidedMay 15, 2026
DocketF089962
StatusUnpublished

This text of Marriage of Ogden CA5 (Marriage of Ogden CA5) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Marriage of Ogden CA5, (Cal. Ct. App. 2026).

Opinion

Filed 5/15/26 Marriage of Ogden CA5

NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FIFTH APPELLATE DISTRICT

In re the Marriage of JILL ANN OGDEN and GILBERT LAWRENCE OGDEN.

JILL ANN OGDEN, F089962

Respondent, (Super. Ct. No. FL-21-002214)

v. OPINION GILBERT LAWRENCE OGDEN,

Appellant.

APPEAL from a judgment of the Superior Court of Stanislaus County. Joseph R. Distaso, Judge. Gilbert Lawrence Ogden, in pro. per., for Appellant. No appearance for Respondent. -ooOoo- INTRODUCTION In this marital dissolution case, appellant (Husband) appeals the trial court’s order characterizing an investment account (E*TRADE) as community property in conjunction with an earlier ruling valuing respondent’s (Wife) equity share of a second investment account (Webull) to which Husband had apparently transferred most of the original value in the E*TRADE account. As we will explain, these rulings, even considered collectively, are nonappealable interlocutory orders, we decline to exercise our power to treat the purported appeal as a petition for a writ of mandate, and we accordingly dismiss the appeal because we lack jurisdiction over it.1 FACTUAL BACKGROUND Husband and Wife married on July 2, 1994, and they separated on August 25, 2021, when Wife filed a petition for marital dissolution. They have no minor children. The matter proceeded to a long-cause hearing in April 2025. Relevant to this appeal, the parties disputed the characterization of an E*TRADE investment account. Husband argued the E*TRADE account was his separate property because the marriage was void for lack of the requisite blood tests required to obtain a marriage license in 1994 under a repealed Family Code statute. (Fam. Code, former §§ 580, 581; see Stats. 1994, ch. 197, § 1, p. 1740 [repealed].) Husband also maintained that, even if the E*TRADE account was community property, it was transmuted to his separate property pursuant to an account transfer request signed by both Husband and Wife in 2016. I. Relevant Trial Testimony A. E*TRADE Investment Account: Characterization Dispute To establish the E*TRADE account was not community property, Husband argued the marriage was void. According to Husband, he had never undergone the blood test required under a repealed statute to obtain a marriage license in 1994. Wife testified she

1 Wife did not file a responsive brief in this appeal.

2. believed the marriage was valid at all times between the date of their marriage and separation. She could not recall whether they underwent blood tests to obtain the marriage license. The court declined to find the marriage void. The court reasoned that even if the marriage was void or voidable, Husband and Wife had lived together as a married couple between 1994 and 2021, and the court could divide property the couple acquired during that time as quasi-marital property. The court explained that as the putative spouse, Wife could request the property be divided as if it were community property. As such, the court ruled that either the marriage was valid, or if not, the parties acted as if the marriage was valid from the date of marriage to the date of separation, the couple’s assets would be divided as quasi-marital property. Wife testified the E*TRADE account was originally opened during their marriage. Husband testified he opened the brokerage account in his name only, and it was primarily funded with money he had acquired before marriage—but he had no documentation showing when the account was opened. Although he “added some” money to the account from his marital earnings, most of the account balance was attributable to gains in the value of the holdings. Husband testified he opened the account with ShareBuilder, which was later acquired by ING Direct. Then, in 2008, around the time Husband was recovering from a stroke, ING Direct was acquired by Capital One Investments (Capital One). When that happened, Capital One required Husband to complete paperwork transferring the account to Capital One. In completing that paperwork, Husband marked a box indicating the account was “‘community’” instead of indicating the account was held individually, and Wife’s name was added to the account mistakenly. It remained a joint account with Capital One from 2008 to 2016. Husband testified that in 2016, after he realized his mistake in adding Wife to the investment account, he asked that Wife agree to transfer the account’s holdings to his sole, individual account. According to Husband, Wife agreed because she had not

3. contributed any of her earnings to the account. The court admitted Husband’s exhibit No. 1, a Capital One form entitled “Transfer Assets Between Capital One Investing Accounts.” The form identified Husband and Wife as joint account owners, and indicated the funds in the account were to be transferred to another Capital One investment account held in Husband’s name only. The form required all current accountholders to attest to the following to effect the transfer: “I hereby relinquish all right, title and interest in said securities and/or monies and I irrevocably release and discharge you of any claims by me or my legal representatives with reference thereto, including and disposition thereof of such property.” (Boldface added.) Both Husband and Wife, as joint owners, signed the form to allow Capital One to transfer the account holdings to the new individual account in Husband’s name only. According to Wife’s testimony, she signed this document believing it gave Husband permission to manage the account, not that she was waiving a community property interest in the account holdings. When she signed the company’s transfer form, she believed there was between $200,000 and $300,000 in the account. Although she signed the form voluntarily, she noted she was subject to her Husband’s “serious nagging” to do so. B. Dispute Over E*TRADE and Webull Account Value Capital One Investments was later acquired by E*TRADE, and Husband opened several E*TRADE accounts to organize different types of investments. During the trial, the court asked Husband about the current balances in the E*TRADE accounts, and Husband stated the overall balance was “really low” and the “stocks are all Chinese stocks” that “crashed” about “100-something percent.” In addition, some of the E*TRADE accounts were “locked” because the companies he “bought into” were small, the government would not let them be traded, and he could not get into those accounts. Husband represented the balance in the E*TRADE accounts was “less than $100,000.”

4. Wife’s counsel disputed that valuation because around the time of separation, in September 2021, the E*TRADE account had over $800,000. The court indicated it would need all the balances before it could make a ruling, and the court ordered Husband to produce E*TRADE account statements from March 2024 to May 2025 for the next day’s hearing. When the issue was revisited the following day, Husband represented he had difficulty obtaining the E*TRADE account statements. He had one statement for the E*TRADE account holding Chinese stock, which had a value of $4,531. He represented the government had restricted the sale of those stocks, and nothing could be done with them presently. After the couple separated, Husband had transferred all other funds and/or holdings in the E*TRADE accounts to a Webull account, the stock market crashed, and he lost about 50 percent of the value in the account. Husband represented his Webull account had $418,406 as of March 31, 2025, which Wife’s counsel confirmed.

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