In Wilshire Associates v. Grebow (1998) 64 Cal.App.4th 453, the plaintiff lessor sued the wife of the guarantor of a lease, based solely on her husband's obligations as a guarantor. The plaintiff contended the wife was liable for the husband's personal guarantee under Family Code section 910 because that statute provided the wife was responsible for her husband's obligations to the extent of their community property. (Wilshire Associates, at p. 455.) The appellate court affirmed summary judgment in favor of the wife on the ground there was no cause of action in California based on community property liability under section 910. (Wilshire Associates, at p. 457.) The court noted the plaintiff had sued the wife not because she was personally liable on the guarantee, "but to facilitate its postjudgment recovery of money damages should it succeed on its claim" against the husband. (Id. at p. 455.) The appellate court relied on Reynolds & Reynolds Co. v. Universal Forms, Labels & Systems, Inc. (C.D.Cal.1997) 965 F.Supp. 1392, in which the court held: "Where both spouses are named in litigation, and where one spouse is included solely in the capacity as a community representative, that spouse has no personal liability, that spouse's separate property cannot be reached for the type of debt alleged, and such spouse does not desire to participate in the litigation, there appears to be no legitimate advantage to plaintiff in forcing the unwilling spouse to participate in the litigation." (Id. at p. 1397; Wilshire Associates, at p. 457.)