What happens when two people marry, one works and pays the tuition for medical school and supports the other and then after the other party graduates from medical school, he decides he wants a divorce? The answer is the doctrine of “equitable reimbursement,” which was announced by the state Supreme Court in Bold v. Bold, 574 A.2d 552 (Pa. 1990).
The parties were married in 1974 and Mrs. Bold had a college degree at the time of marriage. Her husband had completed some college and from 1974 through 1979, Mr. Bold pursued a course of college study and graduated from chiropractic college. During the time when Mr. Bold was in school, Mrs. Bold earned more than $97,000. Mrs. Bold filed for divorce in 1981 and the Court awarded her $33,000 in “reimbursement equity”. The Bold court looked for guidance to Lehmicke v. Lehmicke, 489 A.2d 782 (Pa. Super. 1985) where the wife was awarded equitable reimbursement for the monies she expended while her husband was in medical school. Subsequent to the Bold case, the state Supreme Court again affirmed the doctrine of equitable reimbursement in Zullo v. Zullo, 613 A.2d 544 (Pa. 1992).
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