Pittman v. Pittman, 754 S.E.2d 501

Marriage from 2000 to separation 2007; Wife sought divorce on adultery and to characterize Pittman Professional Land Surveying, Inc. as marital property.
Business began in 1996 pre-marriage; Wife assisted with billing, accounting, and some field duties; both pooled funds and shared management.
In-marriage participation: Wife reduced nursing hours, salary decisions were joint, and Wife earned substantial salary from the Business.
Premarital contributions and guarantees: geodimeters purchased before marriage with debt; both signed an unlimited guaranty in 2002.
Family court found the Business transmuted to marital property and valued and equitably apportioned in the marital estate.
Court of Appeals partially affirmed, but this Court held premarital conduct wrong for transmutation analysis and affirmed transmutation based on marriage conduct

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Business was transmuted into marital property	Pittman contends no transmutation; premarital conduct cannot establish it	Pittman argues the record shows mutual intent to treat the Business as marital property	Transmutation established based on marriage conduct; premarital conduct improperly considered
Whether Pittman was entitled to special equity or premarital credit	Husband seeks special equity or premarital value credit	Court should include full value and deny special equity; adjust overall division	No special equity; overall equitable apportionment deemed fair; premarital credit not separately awarded

Edwards v. Edwards, 384 S.C. 179 (Ct.App. 2009) (transmutation factors and marital assets evidence)
Lewis v. Lewis, 892 S.C. 381 (2011) (appellate deferential review of family court credibility findings)
Dawkins v. Dawkins, 386 S.C. 169 (2010) (sole method for accounting for special equity in marital property)
Franks v. Frank, 311 S.C. 454 (Ct.App. 1993) (transfer of premarital funds to marital use evidences transmutation)