In re the Marriage of: Melissa J. Dickerson and Kent E. Dickerson, 33863-1

Kent and Melissa married in June 2007, separated in September 2014, and Melissa filed for dissolution.
Each spouse brought separate assets into the marriage (checking accounts, homes, T. Rowe Price accounts).
Evidence showed the parties agreed to pool assets, deposited earnings into a joint USAA account, converted Kent's Texas home to community property, rented it and deposited rents into the USAA account, and created a community obligation by withdrawing equity.
A T. Rowe Price account is disputed: Kent produced no pre-marriage statements and his account statements show a $0 balance in Nov 2007 and $421,815 in Dec 2007.
The trial court found the parties intended to pool all separate property into community property and divided marital property roughly equally; Kent appealed.

Issue	Plaintiff's Argument (Dickerson)	Defendant's Argument (Smith)	Held
Characterization of T. Rowe Price account: community or separate property	Account is Kent's separate property; he testified no marital deposits were made	Kent failed to trace the Dec 2007 deposit to separate funds; documentary evidence undermines his testimony and shows pooling	Affirmed: account characterized as community; Kent did not meet the clear-and-convincing tracing burden
Request for attorney fees on appeal	Kent sought fees in his brief conclusion	Smith opposed; Kent provided no supporting argument or authority	Denied: fee request was procedurally improper and unsupported

In re Marriage of Kile, 186 Wn. App. 864 (character of asset determined at date of acquisition)
In re Marriage of Chumbley, 150 Wn.2d 1 (party claiming separate property must trace to separate source by clear and convincing evidence)
Crites v. Koch, 49 Wn. App. 171 (failure to make a factual finding construed against the party with burden of proof)
Osborne v. Seymour, 164 Wn. App. 820 (procedural requirements for attorney-fee requests on appeal)