Zork Hardware Co. v. Gottlieb
In Zork Hardware Co. v. Gottlieb, 170 Ariz. 5, 821 P.2d 272 (App. 1991), the husband alone guaranteed the debts of a hardware store, and when the store defaulted, the creditor obtained a judgment in Texas against the husband.
To compromise the judgment, the husband signed a promissory note in the creditor's favor but when he later defaulted, the creditor sued both the husband and his wife. Id. at 6, 821 P.2d at 273.
The Court affirmed a judgment against the husband's separate property and rejected the notion that "one spouse acting unilaterally could, by signing a promissory note during marriage, convert a separate obligation into a community one." Id.