Direct Capital Corp. v. Brooks, 14 Cal. App. 5th 1168

DCC leased office computer equipment in 2013 to Mary Brooks (a practicing immigration attorney) and obtained a judgment after she defaulted; DCC later sought to garnish wages of her husband, Grant Brooks.
DCC argued the lease debt was incurred during marriage and was a community obligation because it was for "necessaries of life."
Grant opposed garnishment, arguing (1) the debt was not for "necessaries of life" (computers are not necessary) and (2) he had filed for divorce, which he claimed affected jurisdiction; a divorce judgment was later entered.
The trial court found the debt was incurred before separation, that the computers were necessaries of life for the particular marriage because they were necessary to Mary’s law practice (which generated community income), and granted garnishment (stayed pending appeal).
On appeal the court reviewed the legal distinction between "necessaries of life" (pre-separation) and "common necessaries of life" (post-separation), deferred to the trial court’s factfinding about the marital station in life, and affirmed the garnishment order.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether spouse is liable under Fam. Code §914(a)(1) for another spouse’s debt when debt was for "necessaries of life" incurred before separation	DCC: The leased computers were necessaries because they were required for Mary’s law practice which produced community income	Grant: Computers are conveniences, not "necessaries of life," and thus his separate wages are not liable	Affirmed — court held pre-separation "necessaries" uses a station-in-life test; substantial evidence supports that the computers were necessary to that marriage’s station in life, so Grant is liable
Whether "necessaries of life" equals "common necessaries of life" or differs	DCC: (at times conflated the terms) but relied on debt meeting the statute	Grant: Argued narrow meaning like "common necessaries" (universally necessary items) so computers do not qualify	Held — statutory text and precedent distinguish terms: "necessaries" (pre-separation) is broader and fact-specific (station in life), while "common necessaries" (post-separation) is narrow and universal
Standard of review for trial court’s finding that items were necessary to the marriage’s station in life	DCC: Trial court's factual determination should be upheld	Grant: Contended court erred as a matter of law that computers qualify	Held — trial court’s factual determination reviewed for substantial evidence/deferential review and was not disturbed

Collection Bureau of San Jose v. Rumsey, 24 Cal.4th 301 (section 914 is an exception to general rule that separate property is not liable for spouse’s debts)
Wisnom v. McCarthy, 48 Cal.App. 697 (station-in-life test: "necessaries" depend on economic and social position of family)
Ratzlaff v. Portillo, 14 Cal.App.3d 1013 (distinguishing "necessaries" from "common necessaries"; common necessaries are universally required to sustain life)
In re Marriage of Higgason, 10 Cal.3d 476 (discussing liability for support according to parties’ station in life)
Sanker v. Humborg, 48 Cal.App.2d 205 (fact-specific determination of necessaries is within trial court’s discretion)