Bliss v. Bliss

In Bliss v. Bliss, 127 Idaho 170, 898 P.2d 1081, 1084 (Idaho 1995), the court found that reimbursement to the community was improper absent proof of enhancement to the separate property. There, the husband incurred a prenuptial debt and used $ 13,000 in community funds to pay off this separate debt. Id. at 1082. The magistrate at the initial proceeding found that the husband's separate estate was enhanced by community funds through the elimination of this separate debt. Id. at 1084. Consequently, the magistrate determined that the community was entitled to reimbursement. Id. at 1083. The Supreme Court of Idaho reversed. Id. at 1086. It held that although the husband's net value may have been enhanced, the community funds did not enhance the value of identifiable property. Id. at 1081.