In Gristy v. Hudgens, 23 Ariz. 339, 341, 348, 203 P. 569, 570, 572 (1922), abrogated by Day v. Clark, 36 Ariz. 353, 357, 285 P. 682, 683 (1930), the Arizona Supreme Court considered a case in which life-insurance premiums potentially had been paid with community-property funds, but a third party had been designated as the beneficiary. It held that even if the premiums had been paid with community property, any insurance benefits paid to a non-spouse did not defraud the wife, in part because there existed "no showing that the wife had not received even more than her share of the community property." Gristy, 23 Ariz. at 348, 203 P. at 572.