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26 California opinions name it 1 courts 1998–2025 10 in the last five years
The cases below were cited by California courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
Walrath v. Walrathgreen2 sentences2023(In re Marriage of Walrath (1998) 17 Cal.4th 907, 919 (Walrath).) In Walrath, the court addressed the question whether a party’s right to reimbursement under section 2640 was “limited to the original community property to which the contribution was made” or could instead be traced to other community assets that were obtained when the original community asset was refinanced. 2023(In re Marriage of Walrath (1998) 17 Cal.4th 907, 919 (Walrath).) In Walrath, the court addressed the question whether a party’s right to reimbursement under section 2640 was “limited to the original community property to which the contribution was made” or could instead be traced to other community assets that were obtained when the original community asset was refinanced. | 6 | 9 |
In Re Marriage of Braudgreen2 sentences2021(In re Marriage of Braud (1996) 45 Cal.App.4th 797, 823 .) Tracing Separate Property Contributions Tracing is an indispensable prerequisite to any reimbursement under section 2640. “[A] contributing spouse cannot randomly seek reimbursement from any asset through which his or her separate property contribution has at some time passed.” (In re Marriage of Walrath (1998) 17 Cal.4th 907, 923 (Walrath).) The party seeking reimbursement has the burden to trace his or her separate property contributions to specific assets. 2021(In re Marriage of Braud (1996) 45 Cal.App.4th 797, 823 .) Tracing Separate Property Contributions Tracing is an indispensable prerequisite to any reimbursement under section 2640. “[A] contributing spouse cannot randomly seek reimbursement from any asset through which his or her separate property contribution has at some time passed.” (In re Marriage of Walrath (1998) 17 Cal.4th 907, 923 (Walrath).) The party seeking reimbursement has the burden to trace his or her separate property contributions to specific assets. | 4 | 7 |
Lucy v. Cochrangreen2 sentences2021As our Supreme Court explained in Walrath, “a reimbursement right under section 2640 only arises once the property becomes community property.” (Walrath, supra, 17 Cal.4th at p. 920 .) After transmutation from separate to community property, “section 2640 provides a right to reimbursement upon dissolution for the spouse who contributed separate property to [its] acquisition . . . .” (In re Marriage of Weaver (2005) 127 Cal.App.4th 858, 865 .) “Commingling of separate and community property does not alter the status of the 12 separate property interest so long as it can be traced to its separat 2021As our Supreme Court explained in Walrath, “a reimbursement right under section 2640 only arises once the property becomes community property.” (Walrath, supra, 17 Cal.4th at p. 920 .) After transmutation from separate to community property, “section 2640 provides a right to reimbursement upon dissolution for the spouse who contributed separate property to [its] acquisition . . . .” (In re Marriage of Weaver (2005) 127 Cal.App.4th 858, 865 .) “Commingling of separate and community property does not alter the status of the 12 separate property interest so long as it can be traced to its separat | 2 | 4 |
In Re Marriage of Wittgreen2 sentences2025(In re Marriage of Witt (1987) 197 Cal.App.3d 103, 108 [the statute “creates a substantive right of reimbursement in the contributing spouse which can be relinquished only by an express written waiver”].) There was no evidence at trial of a written waiver by Husband of the right to reimbursement, and no evidence Husband made the downpayment as a gift to the community. 2002(E.g., In re Marriage of Perkal, supra, 203 Cal.App.3d at pp. 1203-1204 [deed transferring separate property to community as “a gift” does not waive reimbursement rights]; In re Marriage of Witt, supra, 197 Cal.App.3d 103, 108 [gift of separate property (farm) to community did not waive right of reimbursement]; In re Marriage of Kahan (1985) 174 Cal.App.3d 63, 72 [ 219 Cal.Rptr. 700 ] [waiver must be made in separate writing and cannot be made in “the same deed that created a presumption of community property”].) Spousal Support Wife was awarded $2,083 a month support for five years pursuant t | 2 | 2 |
Marriage G.C. v. R.W.green2 sentences2023(See In re Marriage of G.C. & R.W. (2018) 23 Cal.App.5th 1, 23 [“Since the relevant facts are undisputed, and the issue on appeal turns on whether the trial court properly applied the law governing the characterization of assets upon dissolution, we apply the de novo standard of review.”].) Applying this standard, we hold the court correctly ruled Motiska’s sale of Neon Palm to Buxup—at the sale price of $1 set by Motiska—was not a contribution to the acquisition of property of the community estate that would entitle him to reimbursement under section 2640. 2023(See In re Marriage of G.C. & R.W. (2018) 23 Cal.App.5th 1, 23 [“Since the relevant facts are undisputed, and the issue on appeal turns on whether the trial court properly applied the law governing the characterization of assets upon dissolution, we apply the de novo standard of review.”].) Applying this standard, we hold the court correctly ruled Motiska’s sale of Neon Palm to Buxup—at the sale price of $1 set by Motiska—was not a contribution to the acquisition of property of the community estate that would entitle him to reimbursement under section 2640. | 2 | 2 |
In Re the Marriage of Dee & Stollgreen2 sentences2016(Walrath, supra, 17 Cal.4th at p. 920, fn. 5 ; In re Marriage of Braud (1996) 45 Cal.App.4th 797, 823-824 (Braud); In re Marriage of Stoll (1998) 63 Cal.App.4th 837, 841 (Stoll).) 11 he should obtain a right to reimbursement for community contributions under section 2640.) "Whether the spouse claiming a separate property interest has adequately traced an asset to a separate property source is a question of fact for the trial court, and its finding must be upheld if supported by substantial evidence." ( Braud, supra, 45 Cal.App.4th 797, 823 .) A reviewing court examines the record in the light 2015"It is hornbook California family law that tracing is done either directly, or by a process of elimination whereby a spouse shows the exhaustion of available community funds at the time of acquisition." (In re Marriage of Stoll (1998) 63 Cal.App.4th 837, 841 (Stoll).)20 The first method is referred to as direct tracing. | 2 | 2 |
In Re Marriage of Weavergreen2 sentences2021As our Supreme Court explained in Walrath, “a reimbursement right under section 2640 only arises once the property becomes community property.” (Walrath, supra, 17 Cal.4th at p. 920 .) After transmutation from separate to community property, “section 2640 provides a right to reimbursement upon dissolution for the spouse who contributed separate property to [its] acquisition . . . .” (In re Marriage of Weaver (2005) 127 Cal.App.4th 858, 865 .) “Commingling of separate and community property does not alter the status of the 12 separate property interest so long as it can be traced to its separat 2021As our Supreme Court explained in Walrath, “a reimbursement right under section 2640 only arises once the property becomes community property.” (Walrath, supra, 17 Cal.4th at p. 920 .) After transmutation from separate to community property, “section 2640 provides a right to reimbursement upon dissolution for the spouse who contributed separate property to [its] acquisition . . . .” (In re Marriage of Weaver (2005) 127 Cal.App.4th 858, 865 .) “Commingling of separate and community property does not alter the status of the 12 separate property interest so long as it can be traced to its separat | 1 | 5 |
In Re Marriage of Mixgreen2 sentences2016(See, supra, 64 Cal.2d 778, 783 ; Mix, supra, 14 Cal.3d 604, 612 ; Estate of Murphy (1976) 15 Cal.3d 907, 918 ; Hicks v. Hicks (1962) 211 Cal.App.2d 144, 157 .) The same tracing methodologies are now employed in cases where tracing is conducted to obtain reimbursement under section 2640. 2016(See, supra, 64 Cal.2d 778, 783 ; Mix, supra, 14 Cal.3d 604, 612 ; Estate of Murphy (1976) 15 Cal.3d 907, 918 ; Hicks v. Hicks (1962) 211 Cal.App.2d 144, 157 .) The same tracing methodologies are now employed in cases where tracing is conducted to obtain reimbursement under section 2640. | 1 | 2 |
See v. Seegreen2 sentences2016(See, supra, 64 Cal.2d 778, 783 ; Mix, supra, 14 Cal.3d 604, 612 ; Estate of Murphy (1976) 15 Cal.3d 907, 918 ; Hicks v. Hicks (1962) 211 Cal.App.2d 144, 157 .) The same tracing methodologies are now employed in cases where tracing is conducted to obtain reimbursement under section 2640. 2015(See v. See (1966) 64 Cal.2d 778, 783 (See); In re Marriage of Mix (1975) 14 Cal.3d 604, 612 (Mix); Estate of Murphy (1976) 15 Cal.3d 907, 918 ; Hicks v. Hicks (1962) 211 Cal.App.2d 144, 157 .) However, those same tracing methodologies are now employed in cases where tracing is conducted to obtain reimbursement under section 2640. | 1 | 2 |
Marriage of Bonvinogreen2 sentences2018However, reimbursement awarded pursuant to section 2640 may not include *24 any amounts attributable to appreciation. 19 (See, e.g., Bonvino , supra , 241 Cal.App.4th at p. 1432, 194 Cal.Rptr.3d 754 .) Therefore, on remand, the trial court shall divide the value of the appreciation of the marital residence evenly, as a community asset. 2018However, reimbursement awarded pursuant to section 2640 may not include *24 any amounts attributable to appreciation. 19 (See, e.g., Bonvino , supra , 241 Cal.App.4th at p. 1432, 194 Cal.Rptr.3d 754 .) Therefore, on remand, the trial court shall divide the value of the appreciation of the marital residence evenly, as a community asset. | 1 | 1 |
Medical Board v. Superior Courtgreen2 sentences2015Priority of Family Code Section 852 We conclude that the transmutation provisions of section 852 must be satisfied to change the character of separate property to community property before the reimbursement provisions of section 2640 apply. *1433 “It is a fundamental rule of statutory construction that a court ‘should ascertain the intent of the Legislature so as to effectuate the purpose of the law.’ [Citation.] In determining such intent ‘[t]he court turns first to the words themselves for the answer.’ [Citation.]” (Estate of MacDonald, supra, 51 Cal.3d at p. 268 .) “ ‘ “We must select the c 2015Priority of Family Code Section 852 We conclude that the transmutation provisions of section 852 must be satisfied to change the character of separate property to community property before the reimbursement provisions of section 2640 apply. *1433 “It is a fundamental rule of statutory construction that a court ‘should ascertain the intent of the Legislature so as to effectuate the purpose of the law.’ [Citation.] In determining such intent ‘[t]he court turns first to the words themselves for the answer.’ [Citation.]” (Estate of MacDonald, supra, 51 Cal.3d at p. 268 .) “ ‘ “We must select the c | 1 | 1 |
| Koshak v. Malekgreen | 1 | 1 |
| In Re Marriage of Weissgreen | 1 | 1 |
| In Re Marriage of Kahangreen | 1 | 1 |
| In Re Marriage of Schoettgengreen | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in California. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
In Re Marriage of Marsden
green
2 sentences2023(In re Marriage of Marsden (1982) 130 Cal.App.3d 426, 441 .) Whether the spouse seeking reimbursement of a contribution of separate property to a community asset “has adequately [met his or her burden of tracing] an asset to a separate property source is a question of fact and the trial court’s holding on the matter must be upheld if supported by substantial evidence.” (In re Marriage of Braud (1996) 45 Cal.App.4th 797, 823 (Braud).) Substantial evidence is that which “ ‘ “ ‘a reasonable mind might accept as adequate to support a conclusion.’ ” ’ ” (Ogundare v. Department of Industrial Relatio 2016He did not provide proof that he made contributions qualifying him for reimbursement under section 2640, subdivision (b), for his "contributions to the acquisition of property of the 10 Under In re Marriage of Moore (1980) 28 Cal.3d 366, 371-372 , the community has a pro tanto community property interest in acquired property " 'in the ratio that the payments on the purchase price with community funds bear to the payments made with separate funds.' " (See In re Marriage of Marsden (1982) 130 Cal.App.3d 426, 436-439 .) 22 community property estate to the extent the party traces the contributions | 2 | 2016–2023 |
In Re Marriage of Brooks & Robinson
red
2 sentences2021(In re Marriage of Fossum (2011) 192 Cal.App.4th 336, 345 , quoting In re Marriage of Brooks & Robinson (2008) 169 Cal.App.4th 176,189 , abrogated on other grounds by In re Marriage of Valli (2014) 58 Cal.4th 1396, 1405 .) The fact that these properties were recharacterized as community property through valid transmutations does not defeat Husband’s reimbursement claim under section 2640; it is a prerequisite to that claim. 2021(In re Marriage of Fossum (2011) 192 Cal.App.4th 336, 345 , quoting In re Marriage of Brooks & Robinson (2008) 169 Cal.App.4th 176,189 , abrogated on other grounds by In re Marriage of Valli (2014) 58 Cal.4th 1396, 1405 .) The fact that these properties were recharacterized as community property through valid transmutations does not defeat Husband’s reimbursement claim under section 2640; it is a prerequisite to that claim. | 2 | 2021–2021 |
Fossum v. Fossum
green
2 sentences2021(In re Marriage of Fossum (2011) 192 Cal.App.4th 336, 345 , quoting In re Marriage of Brooks & Robinson (2008) 169 Cal.App.4th 176,189 , abrogated on other grounds by In re Marriage of Valli (2014) 58 Cal.4th 1396, 1405 .) The fact that these properties were recharacterized as community property through valid transmutations does not defeat Husband’s reimbursement claim under section 2640; it is a prerequisite to that claim. 2021(In re Marriage of Fossum (2011) 192 Cal.App.4th 336, 345 , quoting In re Marriage of Brooks & Robinson (2008) 169 Cal.App.4th 176,189 , abrogated on other grounds by In re Marriage of Valli (2014) 58 Cal.4th 1396, 1405 .) The fact that these properties were recharacterized as community property through valid transmutations does not defeat Husband’s reimbursement claim under section 2640; it is a prerequisite to that claim. | 2 | 2021–2021 |
Marr. of Valli
green
2 sentences2021(In re Marriage of Fossum (2011) 192 Cal.App.4th 336, 345 , quoting In re Marriage of Brooks & Robinson (2008) 169 Cal.App.4th 176,189 , abrogated on other grounds by In re Marriage of Valli (2014) 58 Cal.4th 1396, 1405 .) The fact that these properties were recharacterized as community property through valid transmutations does not defeat Husband’s reimbursement claim under section 2640; it is a prerequisite to that claim. 2021(In re Marriage of Fossum (2011) 192 Cal.App.4th 336, 345 , quoting In re Marriage of Brooks & Robinson (2008) 169 Cal.App.4th 176,189 , abrogated on other grounds by In re Marriage of Valli (2014) 58 Cal.4th 1396, 1405 .) The fact that these properties were recharacterized as community property through valid transmutations does not defeat Husband’s reimbursement claim under section 2640; it is a prerequisite to that claim. | 2 | 2021–2021 |
Union Bank v. Murphy
green
2 sentences2016(See, supra, 64 Cal.2d 778, 783 ; Mix, supra, 14 Cal.3d 604, 612 ; Estate of Murphy (1976) 15 Cal.3d 907, 918 ; Hicks v. Hicks (1962) 211 Cal.App.2d 144, 157 .) The same tracing methodologies are now employed in cases where tracing is conducted to obtain reimbursement under section 2640. 2015(See v. See (1966) 64 Cal.2d 778, 783 (See); In re Marriage of Mix (1975) 14 Cal.3d 604, 612 (Mix); Estate of Murphy (1976) 15 Cal.3d 907, 918 ; Hicks v. Hicks (1962) 211 Cal.App.2d 144, 157 .) However, those same tracing methodologies are now employed in cases where tracing is conducted to obtain reimbursement under section 2640. | 2 | 2015–2016 |
Hicks v. Hicks
green
2 sentences2016(See, supra, 64 Cal.2d 778, 783 ; Mix, supra, 14 Cal.3d 604, 612 ; Estate of Murphy (1976) 15 Cal.3d 907, 918 ; Hicks v. Hicks (1962) 211 Cal.App.2d 144, 157 .) The same tracing methodologies are now employed in cases where tracing is conducted to obtain reimbursement under section 2640. 2015(See v. See (1966) 64 Cal.2d 778, 783 (See); In re Marriage of Mix (1975) 14 Cal.3d 604, 612 (Mix); Estate of Murphy (1976) 15 Cal.3d 907, 918 ; Hicks v. Hicks (1962) 211 Cal.App.2d 144, 157 .) However, those same tracing methodologies are now employed in cases where tracing is conducted to obtain reimbursement under section 2640. | 2 | 2015–2016 |
In Re Marriage of Haines
red
2 sentences2015(In re Marriage of Mathews (2005) 133 Cal.App.4th 624, 629 ; In re Marriage of Haines (1995) 33 Cal.App.4th 277, 293-294 .) As part of Frick's attempt to trace her separate property into the Jack White account and then into the purchase of the San Antonio and California St. properties, Frick argued that because Furrh had transferred Frick's separate property funds into the Jack White account in violation of his fiduciary duty to her, Furrh could not claim that Frick's separate property funds were transmuted to community property when they were comingled by Furrh in the Jack White account. 2002(In re Marriage of Haines, supra, 33 Cal.App.4th 277, 297 .) We also reject Sandra’s contention that the preparation and acceptance of the promissory note and deed of trust are a substitute for a written waiver of her reimbursement rights under section 2640, subdivision (b). | 2 | 2002–2015 |
In Re Marriage of Frick
green
2 sentences2023Rather, section 2640 required that she trace those funds to a separate property source and not to gifts of cash from Husband without a writing in which he expressly declared he was transmuting the funds to her as her separate property. 13 Because we addressed above the trial court’s award to Wife of section 2640 reimbursement for cash gifts by Husband presumably totaling $400,000, which she contributed toward the down payment for the Property purchase, we now address only the remainder of $150,000 of the court’s total $550,000 section 2640 reimbursement award to her, which amount it implicitly 2023Rather, section 2640 required that she trace those funds to a separate property source and not to gifts of cash from Husband without a writing in which he expressly declared he was transmuting the funds to her as her separate property. 13 Because we addressed above the trial court’s award to Wife of section 2640 reimbursement for cash gifts by Husband presumably totaling $400,000, which she contributed toward the down payment for the Property purchase, we now address only the remainder of $150,000 of the court’s total $550,000 section 2640 reimbursement award to her, which amount it implicitly | 1 | 2023–2023 |
Los Angeles County Department of Children & Family v. Jose C.
green
1 sentence2023(Ibid.; Ana C., supra, 204 Cal.App.4th at p. 1329 .) Therefore, construing the evidence and inferences therefrom favorably to support the trial court’s finding, we conclude substantial evidence supports its implied finding that there was adequate documentary evidence in the record tracing Wife’s $100,000 contribution toward the Property purchase price to her separate property and, based thereon, its award of section 2640 reimbursement to Wife in the amount of $100,000.14 Nevertheless, although we conclude substantial evidence supports a section 2640 reimbursement award to Wife for her $100,000 | 1 | 2023–2023 |
Ogundare v. Department of Indust. Relations etc. CA5
green
1 sentence2023(In re Marriage of Marsden (1982) 130 Cal.App.3d 426, 441 .) Whether the spouse seeking reimbursement of a contribution of separate property to a community asset “has adequately [met his or her burden of tracing] an asset to a separate property source is a question of fact and the trial court’s holding on the matter must be upheld if supported by substantial evidence.” (In re Marriage of Braud (1996) 45 Cal.App.4th 797, 823 (Braud).) Substantial evidence is that which “ ‘ “ ‘a reasonable mind might accept as adequate to support a conclusion.’ ” ’ ” (Ogundare v. Department of Industrial Relatio | 1 | 2023–2023 |
In Re Marriage of Epstein
yellow
1 sentence2022Marie 4 See In re Marriage of Epstein (1979) 24 Cal.3d 76 . 5 Section 2640 provides a right of reimbursement for contributions to a community asset traced to separate property funds. 7 attached a declaration from a forensic accountant who came to the preliminary conclusion that $262,288 of the down payment was funded using Marie’s separate property funds. | 1 | 2022–2022 |
In Re Marriage of Whealon
green
1 sentence2022Analysis Several of the arguments raised by Carol on appeal regarding Paul’s entitlement to reimbursement under section 2640 were not presented to the trial court. “[T]o conserve judicial resources, any errors must be brought to the trial court’s attention at the trial level while the error can still be expeditiously corrected.” (In re Marriage of Whealon (1997) 53 Cal.App.4th 132, 144 .) If a party fails to raise a specific objection in the trial court, the challenge is forfeited on appeal and need not be considered by the Court of Appeal. | 1 | 2022–2022 |
In Re Marriage of Koester
green
1 sentence2022Carol’s reliance on In re Marriage of Koester (1999) 73 Cal.App.4th 1032 is entirely misplaced; that case involved transmutation of a husband’s separate property company. | 1 | 2022–2022 |
In Re Marriage of Hinman
green
1 sentence2022(In re Marriage of Hinman (1997) 55 Cal.App.4th 988, 1002 .) We will not consider for the first time on appeal Carol’s claims that the court erred by reimbursing Paul for postseparation contributions to community improvements and for maintenance expenses which she contends did not increase the value of the commercial properties, and by not calculating the community and separate property components of ABX’s contributions to the community property. | 1 | 2022–2022 |
In Re Marriage of Moore
green
1 sentence2016He did not provide proof that he made contributions qualifying him for reimbursement under section 2640, subdivision (b), for his "contributions to the acquisition of property of the 10 Under In re Marriage of Moore (1980) 28 Cal.3d 366, 371-372 , the community has a pro tanto community property interest in acquired property " 'in the ratio that the payments on the purchase price with community funds bear to the payments made with separate funds.' " (See In re Marriage of Marsden (1982) 130 Cal.App.3d 426, 436-439 .) 22 community property estate to the extent the party traces the contributions | 1 | 2016–2016 |
Geraci v. Geraci
green
1 sentence2016(In re Marriage of Geraci (2006) 144 Cal.App.4th 1278, 1286 ; Hogoboom & King, Cal. Practice Guide: Family Law (The Rutter Group 2015) ¶ 8:467, p. 8-172 [“A § 2640 reimbursement award comes off the top of the community property item(s) in question before the C[ommunity] P[roperty] interest in that property is divided”].) “If there is insufficient equity at the time of dissolution in the property to which the contribution was made to fully reimburse the contribution, the entire asset is awarded to the contributing spouse.” (In re Marriage 4 The trial court made rulings about various property it | 1 | 2016–2016 |
In Re Marriage of Carpenter
green
2 sentences2015(Id., subd. (b); Carpenter, supra, 100 Cal.App.4th at p. 427 .) Here, sufficient documentation been available, was to attempt to trace his separate property funds through this second portion of the Internal Revenue Code section 1031 reverse like-kind exchange to establish that some of his separate property funds were paid to the accommodator in 2001 to enable the parties to acquire title to the San Antonio and California St. properties in 2001. 2015(Id., subd. (b); Carpenter, supra, 100 Cal.App.4th at p. 427 .) Here, sufficient documentation been available, was to attempt to trace his separate property funds through this second portion of the Internal Revenue Code section 1031 reverse like-kind exchange to establish that some of his separate property funds were paid to the accommodator in 2001 to enable the parties to acquire title to the San Antonio and California St. properties in 2001. | 1 | 2015–2015 |
In Re Marriage of Mathews
green
1 sentence2015(In re Marriage of Mathews (2005) 133 Cal.App.4th 624, 629 ; In re Marriage of Haines (1995) 33 Cal.App.4th 277, 293-294 .) As part of Frick's attempt to trace her separate property into the Jack White account and then into the purchase of the San Antonio and California St. properties, Frick argued that because Furrh had transferred Frick's separate property funds into the Jack White account in violation of his fiduciary duty to her, Furrh could not claim that Frick's separate property funds were transmuted to community property when they were comingled by Furrh in the Jack White account. | 1 | 2015–2015 |
| Estate of MacDonald green | 1 | 2015–2015 |
In Re Marriage of Feldner
green
1 sentence2015Section 2640, subdivision (b), expressly provides that “the party shall be reimbursed for the party’s contributions to the acquisition of property of the community property estate to the extent the party traces the contributions to a separate property source.” “If the paying spouse simply sits back and does nothing, there will be no reimbursement.” (In re Marriage of Feldner (1995) 40 Cal.App.4th 617, 625 .) Thus, a husband’s claim for reimbursement of his contributions of separate property to acquire or improve the family home was properly denied under section 2640 where the husband failed to | 1 | 2015–2015 |
| Dumas v. Mantle (In re Mantle) green | 1 | 2014–2014 |
| In Re Marriage of Rico neutral | 1 | 2014–2014 |
| Gruen v. Gruen green | 1 | 2014–2014 |
| Richmond v. Dart Industries, Inc. green | 1 | 2014–2014 |
| In Re Marriage of Neal yellow | 1 | 2005–2005 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.