In Capitol Electric Co. v. Campbell, 117 Utah 454, 217 P.2d 392 (1950), the Court addressed the issue of when a spouse can be considered to have implied authority as an agent for the other spouse. In that case the Court agreed with an Oklahoma court that "'while the husband's authority to act for his wife is not implied from the marital relation, nor from the mere fact that he occupied, or managed and controlled, his wife's property, yet in many instances the agency of the husband is inferred from the circumstances . . . .'" Capitol Electric, 117 Utah at 459, 217 P.2d at 394. The Court then stated that "some fact or circumstance is required in addition to the marital relation and management of the wife's property by the husband before an agency of the husband will be inferred." Id.