In re Marriage of Watanabe (Majority)Annotate this Case
Daniel Watanabe and Solveig (Watanabe) Pedersen divorced in 2016. During the marriage, Pedersen inherited a large sum of money and land after her mother passed away. At their dissolution trial, the court held that various real properties were Pedersen’s separate property, despite the fact that both Watanabe’s and Pedersen’s names were on the title for the properties. Watanabe appealed, arguing the trial court erred by failing to apply the joint title gift presumption since the property was acquired in both of their names during marriage. Watanabe also argued the trial court erred by allowing extrinsic evidence of Pedersen’s intent when she quitclaimed her separate property to the community. The Court of Appeals affirmed, holding that the gift presumption did not apply, regardless of whether the property was acquired before or during marriage. The Court of Appeals also held that extrinsic evidence was appropriately admitted to determine whether Pedersen intended to transmute separate property, not to dispute the quitclaim deed itself. After review, the Washington Supreme Court affirmed the Court of Appeals: the joint title gift presumption did not apply regardless of whether the property was acquired before or during marriage. In addition, the Supreme Court held that extrinsic evidence could be admitted to explain the intent of the parties when signing a quitclaim deed to determine whether a party intended to convert separate property into community property.