The Court of Appeals in MACKLIN v. JOHNSON, remarkably addressed whether significant homemaker services by one spouse can be considered as a legal contribution in the equitable distribution of property calculation. In short, the Court concluded that substantial homemaker services are a permissible basis for granting a spouse an equitable interest in the other’s separately-held real property. Factually, husband purchased his home approximately two years before marriage and kept the title under his own name and after a ten year marriage.  Parties had four children during the marriage and wife’s contribution during that period was essentially homemaker services, maintaining the
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