CaseCHERI GINA DAVID v. ROBERT C. DAVID
(Record Number 122145)
FromThe Court of Appeals of Virginia.
CounselDonald K. Butler and Player B. Michelsen (Butler Armstrong, LLP) for appellant.
Charles E. Powers (Batzli Wood & Stiles PC) for appellee.
Assignment of Error
- The Court of Appeals erred in finding that Virginia Code § 20-107.3, as amended, requires a non-owning spouse to prove that the personal efforts of a spouse during marriage are the proximate cause of substantial appreciation in the value of an owning spouse's separate assets in order to establish the increase in value as marital property.