During their ten year marriage, Robert and Alice Crawford bought a house together as tenants by the entireties (a legal term for joint ownership by a married couple).
They separated in 1977. Robert left the house and Alice stayed. She paid the mortgage, real estate taxes and insurance until the house was sold three years later. The net sales proceeds were put into a bank account.
Robert sued for divorce and asked for half the bank account. Alice answered and said she was entitled to a contribution from Robert for the payments she had made on the house.
The trial court found that there was a presumption that the payments made by Alice were a gift to Robert and it divided the bank account equally.
The Court of Appeals said the presumption of gift doctrine should not apply when the parties are separated and that the trial court should consider whether Alice was entitled to some contribution for the payments she made.
When lawyers today ask for “Crawford Credits”, they mean contributions for mortgage, real estate taxes and insurance paid by one spouse for the marital residence after separation.
Crawford v. Crawford, 293 Md. 307 (1982)