In re Marriage of Marsden

In In re Marriage of Marsden, 130 Cal.App.3d 426, 181 Cal.Rptr. 910 (Cal.Ct.App.1982), the property appreciated both before and during marriage. Marsden, 130 Cal. App. 3d at 436. The court elected to credit the separate property interest with the prenuptial appreciation. Id. at 438. Therefore, the community interest was calculated as: reimbursement for contributions to principal plus; the product of the community property principal payments divided by the purchase price times the appreciation in value after marriage. Id. at 439. Translated into an algebraic equation, the Marsden formula is the same as in Drahos v. Rens, except that "A" = appreciation in the value of the property during the marriage.