Section 15.17 Dividends, Stock Splits, and Stock Options

• Library: Family Law Deskbook and 2014 Supp

A. (§15.17) Dividends, Stock Splits, and Stock Options

Cash dividends earned during the marriage on separate property are considered income during the marriage and
are therefore marital. Drikow v. Drikow, 803 S.W.2d 122 (Mo. App. E.D. 1990). But additional stock acquired because of a split of or dividend on separate stock remains separate property. The rationale is that the split does not represent an increase of property owned before the marriage; it is merely a greater number of shares that represent exactly the same ownership and value as existed before the stock split or stock dividend. In re Marriage of Bruske, 656 S.W.2d 288 (Mo. App. W.D. 1983).

Unvested stock options were addressed in Warner v. Warner, 46 S.W.3d 591 (Mo. App. W.D. 2001). In Warner, the husband...