In Re the Marriage of Elam

This case was certified from Division Three of the Court of Appeals pursuant to RCW 2.06-.030(d) on the following question:

To what extent, if any, is there a community interest in the increase in value of separate property due to inflation, where community funds and labor were used to improve the property?

The marriage between Stanley and Norma Elam lasted from April 1972 until its dissolution in October 1979. Mr. Elam entered the marriage without any discernible assets, while Mrs. Elam brought a home purchased in 1967 for $7,500 and a bank balance of $10,000.

At the time of the dissolution,…