Pina v. Pina, 290 Ga. 878

Wife and Husband married in 1998; Wife filed for divorce on December 10, 2008.
Dorchester Avenue property in Dorchester, Massachusetts was pre-marital; Wife transferred it to a trust for three children in 2005.
Trial court found Husband had an equitable interest but that it was negligible; property awarded to Wife as part of equitable division.
Husband argued the trial court abused its discretion by not valuing the Dorchester property and by equitably dividing without sufficient evidence of value.
Record showed Husband performed maintenance on the property but produced no receipts; rent from the property funded mortgage payments and supported the family.
The court determined the increase in value attributable to Husband’s contributions and marital funds was nominal, given lack of valuation at marriage and other evidentiary factors.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the property should be treated as Wife's separate property with only nominal marital increase	Husband contends the court erred by not valuing property and by treating the increase as nominal.	Wife maintains the court properly valued the property through evidence of marital funds and contributions.	Yes; the court correctly found nominal marital increase and did not require current market valuation.
Whether there was sufficient evidence of value given no marriage-time valuation existed	Husband asserts lack of initial valuation prevents calculating increased equity.	Trial court relied on remaining evidentiary factors to determine nominal increase.	Yes; adequate evidence supported the nominal increase finding.
Whether Husband’s contributions and marital funds justify a significant division of the property	Husband argues his maintenance work and marital funds increased value.	Wife asserts contributions were minimal and rents were used to pay mortgage; no joint ownership granted.	Yes; court found contributions left only a nominal increase, supporting the division.

Wright v. Wright, 277 Ga. 133-134 (Ga. 2003) (evidence-based approach to marital asset valuation after premarital property)
Pollard v. Pollard, 279 Ga. 57 (Ga. 2005) (guides equitable division principles for premarital assets)
Hubby v. Hubby, 274 Ga. 525 (Ga. 2001) (recognizes limits on marital funds increasing value of premarital property)
Dupree v. Dupree, 287 Ga. 319 (Ga. 2010) (affirms broad discretion in equitable division factors)
Newman v. Patton, 286 Ga. 805 (Ga. 2010) (reiterates that property acquired during marriage may be subject to equitable division)