June 5, 2026
Court of Appeal, First Appellate District, Division One
The Rule of In re the Marriage of McConnell and Jahnke is that a divorcing party who agrees to assume a joint mortgage in a property settlement cannot be forced to remove the other spouse from the mortgage absent an explicit term requiring it, under circumstances where a settlement agreement awards one spouse the marital home "and all debts thereon" without specifying removal obligations.
May 1, 2026
Court of Appeal, Fourth Appellate District, Division Three
The Rule of In re Marriage of Nishida and Kamoda is that a family law fraud action filed timely in civil court and transferred to family law court may proceed on the merits rather than being dismissed for jurisdictional reasons, under circumstances where the plaintiff filed a civil complaint within the one-year discovery period of Family Code section 2122(a) and the case was properly transferred between departments of the same superior court.
April 6, 2026
Court of Appeal, First Appellate District, Division Four
The Rule of In re Marriage of Jenkins is that a default judgment in a family law case must be set aside when it exceeds the relief requested in the petition and the defaulting party lacked adequate notice of the specific assets to be divided, under circumstances where the petition contained only "TBD" placeholders for property division and the prove-up hearing was conducted based on informal, off-the-record communications without proper notice to the defaulting spouse.