CALIFORNIA FAMILY LAW: COURT APPLIES VAN CAMP FORMULA TO APPRECIATION OF STOCK DURING THE MARRIAGE.

New Case: Marriage of Brooks (2019) Court applied the Van Camp formula to apportion the appreciation of company stock during the marriage. Utilizing this approach, the court characterized the increased value of the stock after marriage as return on Husband’s separate property, finding that Husband did not contribute to the growth of the business after the date of marriage. “[S]ubstantial evidence supports the trial court’s finding that Husband’s earnings during the marriage adequately compensated the community for his efforts, we find no abuse of discretion in applying the Van Camp method of apportionment to find that the increase in the stock value was Husband’s separate property.”

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