Lindsey v. Lindsey, 2017 UT App 38 (Mar. 2, 2017)
In this divorce case, the district court concluded, on summary judgment, that husband’s business interests were separate property. Surveying the exceptions to the general presumption that separate property will not be divided, the court of appeals affirmed, holding that wife’s maintenance of the marital household, standing alone, was insufficient to demonstrate contribution to the opposing party’s pre-marital business interests. The court left open the issue of whether a correctness or deference standard of review would apply to a district court’s pre-trial categorization of marital property.