Intent, Not Contributions: Domestic Partnership Property Classification in Huang v. Kobbeman

I. Introduction

The Alaska Supreme Court’s memorandum opinion in Catherine Huang v. Aaron Kobbeman (No. S‑19027, Mem. Op. & J. No. 2117, Nov. 12, 2025) addresses a recurring and difficult question: when an unmarried couple (here, an engaged couple in a brief cohabiting relationship) acquires a home titled in both names, under what circumstances is that home “domestic partnership property” rather than the separate property of the financially dominant partner?

Although designated as a memorandum opinion and therefore nonprecedential under Alaska Appellate Rule 214(d), the decision provides a detailed application of the domestic partnership property doctrine developed in cases such as Bishop v. Clark, Tolan v. Kimball, Tomal v. Anderson, Reed v. Parrish, and McConville v. Otness. The court vacates a superior court’s determination that a jointly titled house was not partnership property, holding that the trial court:

misapplied the governing “intent” standard,
over‑emphasized financial contributions and the length/quality of the relationship, and
failed to reckon with substantial record evidence of an intent to confer a joint ownership interest.

The case continues Alaska’s line of authority insisting that the parties’ intent—viewed under the totality of the circumstances—controls classification of property in domestic partnership disputes, and that neither title alone nor financial contribution alone is dispositive.

II. Factual and Procedural Background

A. The Relationship and the Home Purchase

Catherine Huang and Aaron Kobbeman met online in 2019, met in person in January 2020, and soon began cohabiting when Kobbeman moved into Huang’s apartment as he prepared to sell his townhouse. The relationship quickly took on a marriage‑trajectory character:

They discussed marriage, buying a house together, and starting a family.
In June 2020 they met with a real estate broker about purchasing a lot for construction; both signed a lot reservation and an intent‑to‑purchase agreement, and Kobbeman paid a $5,000 deposit.
Huang met Kobbeman’s extended family at a reunion; he purchased engagement and wedding rings.
In late January 2021 they jointly applied for and signed a marriage license application (though they never filed it and never married).

As construction neared completion, the parties had to decide how to take title. On March 1, a loan officer emailed Kobbeman asking if Huang would be added to the title “as his wife.” He responded:

“Yes, I would like to add my Fiancé, Catherine Huang to the title.”

They proceeded to close on the home:

Both the warranty deed and the deed of trust identified them as “husband and wife.”
Both parties signed the deed of trust.
Kobbeman provided the $30,000 down payment and paid associated expenses.

The couple moved into the new house together on May 7, 2021. Four days later, an argument culminated in a vehicular collision in front of the property. Police arrested Huang, and she never resided in the home again, returning only to retrieve belongings. Kobbeman continued to live in the house.

B. Superior Court Proceedings

In June 2021, Huang filed a complaint for dissolution of a domestic partnership, asserting that she and Kobbeman had acquired property in the course of their domestic partnership and asking for an equitable division of that property. Kobbeman responded:

characterizing the relationship as mere “intimate and periodic cohabitation,”
denying that a domestic partnership existed, and
denying that any “partnership property” had been acquired.

At the two‑day evidentiary hearing in August–September 2023:

Huang’s testimony. She claimed she was the main point of contact with contractors, estimating that she used 600–1,000 hours of paid leave to oversee construction decisions when Kobbeman was at work. She asserted that the home was intended to be jointly owned as part of their domestic partnership.
Kobbeman’s testimony. He maintained that he was the primary point of contact with contractors, disputed the extent of Huang’s involvement, and emphasized that he alone financed the home. He stated:
- He did intend to marry Huang until the May 11 incident.
- He did not intend the home to be jointly owned current partnership property.
- He believed placing Huang’s name on the deed of trust meant that if “something were to happen” to him, she would then become owner.

The superior court:

found that Huang and Kobbeman were in a domestic partnership, relying on the “totality of the circumstances,” including shared residence and expenses;
but held that the house was not domestic partnership property, characterizing it as Kobbeman’s separate property;
found Huang’s testimony about “sweat equity” non‑credible, concluding she provided no meaningful labor toward construction; and
emphasized that Huang had contributed neither money (“financial skin”) nor credible effort (“sweat equity”) to the project.

The court also downplayed the legal significance of the joint title, treating it as insufficient in itself to establish partnership property, and drew on Tolan v. Kimball to reject a rule that title alone is dispositive.

Huang appealed only the classification of the house; she did not challenge the finding that a domestic partnership existed, nor the finding that Kobbeman did not retain any of her personal property.

III. Summary of the Supreme Court’s Decision

The Alaska Supreme Court vacated the superior court’s determination that the house was not domestic partnership property and remanded for further fact‑finding under the correct legal framework.

Key holdings and conclusions include:

Once a domestic partnership is found, classification of particular property turns on the parties’ intent, assessed under the totality of the circumstances, not merely on financial contribution or relationship duration.
The superior court erred in narrowly focusing on financial contributions and “sweat equity”, and in effectively requiring Huang to have “financial skin or sweat equity” as a prerequisite for her having an ownership interest.
The court also improperly fact‑found when it stated that Huang “did not provide any labor” toward the home, in light of uncontroverted evidence from even Kobbeman that she helped with coordination of construction.
While Tolan v. Kimball correctly says that title is not automatically dispositive, the superior court:
- misapplied Tolan by using it to discount strong evidence of joint intent, rather than to prevent title from trumping that intent, and
- failed to reconcile the significant evidence that Kobbeman that Huang be added to the title and understood that doing so gave her an ownership stake (at least in the event of his death).
The superior court mistakenly treated the short, “tenuous” nature of the relationship as relevant to whether the house belonged to the partnership, although prior Alaska caselaw does not treat relationship length as a factor in the classification of specific assets as partnership property.

Because the parties’ intent is the controlling consideration, and because the superior court failed to properly analyze or even acknowledge significant evidence of an intent to confer a joint ownership interest, the Supreme Court held that it was clear error to find “no intent” to make the home partnership property. The case is remanded for the trial court to re‑evaluate the classification of the home in light of all the evidence and the governing legal standards.

IV. Precedents and Doctrinal Context

A. Overarching Framework: Intent and the Domestic Partnership Doctrine

Alaska’s law on property disputes between unmarried cohabitants — often called “domestic partnership” disputes — has evolved through a line of decisions culminating in Tomal v. Anderson and McConville v. Otness. The central theme is:

Absent a controlling statute or a valid contract between the parties, property in domestic partnership cases “must be classified strictly according to the parties’ intent.” (Tomal v. Anderson, 426 P.3d 915, 923 (Alaska 2018).)

Unlike marital dissolution cases — which are governed by statutes defining “marital property” and requiring equitable division — domestic partnership cases proceed under common-law and equitable principles. The court looks for:

express or implied contracts,
general understandings to share property in a marriage‑like fashion, and
the parties’ conduct evidencing financial and domestic interdependence.

B. Bishop v. Clark and the “Bishop Factors”

Bishop v. Clark, 54 P.3d 804 (Alaska 2002), is the foundational case for identifying when a domestic partnership exists and when property is part of that partnership. There, the court articulated non‑exclusive factors for evaluating whether parties intended a marriage‑like economic partnership:

whether the parties made joint financial arrangements, such as joint savings or checking accounts, or jointly titled property;
whether they filed joint tax returns;
whether they held themselves out as husband and wife;
whether they both contributed to the payment of household expenses;
whether they both contributed to the improvement and maintenance of the disputed property; and
whether they participated in a joint business venture.

Additional considerations include whether the parties raised children together or incurred joint debts. Crucially, the factors are illustrative, not mandatory. They capture “the totality of the circumstances” bearing on whether the parties intended to share property as though married.

In Huang v. Kobbeman, the Supreme Court faults the superior court for both:

treating contributions to the house (Bishop factor 5) as essential to partnership classification; and
failing to appreciate that other Bishop‑type evidence strongly favored viewing the home as jointly owned: joint title; holding out as “husband and wife” on the deed and deed of trust; application for a marriage license; and shared household expenses prior to the move.

C. Reed v. Parrish: Financial Interdependence Without Formal Accounts

In Reed v. Parrish, 286 P.3d 1054 (Alaska 2012), the court confronted an “intermittent relationship” where:

the parties did not file joint taxes,
did not have joint bank accounts, and
one party disproportionately paid expenses.

Nonetheless, the court concluded the parties intended to share property “as though married,” based on:

a jointly leased apartment,
a jointly purchased vehicle, and
shared contributions to household expenses “when [they] had money.”

The wealthier party argued that the lack of formal financial integration (no joint accounts, separate tax returns) defeated any domestic partnership. The court rejected this argument, stressing that the Bishop factors are not exclusive and that financial interdependence can exist without formalized arrangements. The decisive issue remained the parties’ joint intent to share property.

Huang v. Kobbeman expressly relies on Reed to reject the superior court’s emphasis on the absence of “financial skin or sweat equity.” Just as in Reed, the parties here lacked joint bank accounts and made uneven contributions, but they made joint financial decisions about their living arrangements and the purchase of a home. This supports — rather than undermines — an inference of shared intent.

D. Tolan v. Kimball: Title Is Not Automatically Controlling

In Tolan v. Kimball, 33 P.3d 1152 (Alaska 2001), one member of an unmarried couple purchased a house and titled it solely in her own name. The other party contributed labor and resources to the property. The titled owner argued that title should be dispositive of ownership.

The court rejected that argument, warning that making title or possession conclusive:

“tends to operate purely by accident or perhaps by reason of the cunning, anticipatory designs of just one of the parties.”

There, the evidence suggested that despite title being in one name, both parties had contributed to and treated the property as shared. The court found that the titled owner’s refusal to add the other partner’s name reflected “cunning, anticipatory design” rather than any genuine mutual intent to keep the property separate.

In Huang v. Kobbeman, the superior court invoked Tolan largely to discount the significance of Huang’s name on the title. The Supreme Court explains why this was a misreading:

Tolan prevents title from trumping true intent; it does not justify ignoring joint title when other evidence confirms a mutual intent to share ownership.
The “cunning, anticipatory designs” concern is chiefly relevant when only one party’s name appears on title notwithstanding evidence of shared contributions and expectations. It has far less purchase where one party explicitly asked that the other’s name be added as a co‑owner.
Here, unlike in Tolan, the record clearly showed that:
- the lender directly asked whether Huang would be added to the title “as his wife,”
- and Kobbeman replied, “Yes, I would like to add my Fiancé, Catherine Huang to the title,”
- and he later testified that he understood this conveyed ownership rights (at least as a survivorship interest if something happened to him).

The Supreme Court thus faults the trial court for invoking Tolan while ignoring its contextual reasoning and the strong, affirmative evidence that joint title here reflected a genuine intent to share ownership.

E. Tomal v. Anderson and McConville v. Otness: Intent as the Cornerstone

Tomal v. Anderson, 426 P.3d 915 (Alaska 2018), clarified that in domestic partnership cases:

“[A]bsent a controlling statute or a valid contract between the parties, property must be classified strictly according to the parties’ intent.” (Id. at 923.)

It also stressed that a court need not find a “specific intent” regarding each individual asset so long as it finds a general intent to own property together in a marriage‑like relationship. McConville v. Otness, 498 P.3d 632 (Alaska 2021), applied these principles, reaffirming that the Bishop factors guide a holistic assessment of whether the parties intended to create a domestic partnership and own property jointly.

In Huang v. Kobbeman, the Supreme Court invokes Tomal to emphasize two related points:

Once the existence of a domestic partnership is established (as it was here, and as was unchallenged on appeal), courts should look to the parties’ general intent about owning property together in that relationship.
Courts should not over‑privilege technical details like who wrote which checks or the exact duration of the relationship, at the expense of more direct evidence of intent such as:
- joint title,
- marriage license applications,
- the parties’ own explanations of why they put both names on documents, and
- their pattern of shared financial decisions.

F. Standard of Review: Wright v. Dropik

The court cites Wright v. Dropik, 512 P.3d 655 (Alaska 2022), for the proper standard of review in classifying property:

Factual findings about intent are reviewed for clear error.
Classification decisions based on statute, contract, or intent are reviewed de novo as questions of law.

“Clear error” means that, although evidence may support the finding, the appellate court is left with a “definite and firm conviction that a mistake has been made.” Here, the Supreme Court finds such clear error in the trial court’s determination that Huang provided no labor and in its conclusion that there was no intent to make the house partnership property in light of the unaddressed evidence to the contrary.

V. The Court’s Legal Reasoning

A. Reframing the Central Question: Intent to Include the House in the Partnership

The Supreme Court recasts the core issue in precise doctrinal terms:

“Whether the house should be classified as domestic partnership property turns on the parties’ intent.”

Thus, the question is not:

“Who paid for the house?” or
“How long did the relationship last?”

but rather:

“Did these partners, in the context of their domestic partnership, intend to treat this home as part of their jointly owned partnership property?”

The court stresses that this inquiry must be conducted under the “totality of the circumstances” standard articulated in Bishop and its progeny.

B. Misuse of Financial Contributions and “Sweat Equity”

The superior court’s reasoning — that Huang sought “half of the equity in the home without any financial skin or sweat equity in the project” — is directly critiqued.

The Supreme Court acknowledges that contributions to household expenses and to improving/maintaining property are among the Bishop factors, but emphasizes:

Neither the factors nor Alaska law require that a party have made financial or labor contributions as a prerequisite to having a partnership interest in property.
The controlling inquiry remains the parties’ intent; financial and labor contributions are evidentiary, not determinative.

The court points out that:

Even Kobbeman conceded that Huang did assist in coordinating some of the construction work, undermining the finding that she provided “no labor.”
This factual misstatement rose to the level of clear error because it disregarded uncontroverted testimony and skewed the property classification analysis.

C. Failure to Consider Key Intent Evidence

The Supreme Court catalogs the evidence strongly supporting at least some joint ownership intent:

The email where the loan officer asked if Huang would be added to title “as his wife,” and Kobbeman responded affirmatively that he wanted to “add [his] Fiancé, Catherine Huang to the title.”
His testimony that:
- he requested that she be placed on the conveyance documents, and
- he knew the property was jointly titled and that she would become owner if “something happened” to him.
The fact that both the warranty deed and deed of trust listed them as “husband and wife,” and both signed the deed of trust.
The parties’ earlier marriage license application and their mutual intent to marry up until the May 11 incident.
Their shared payment of expenses during cohabitation at Huang’s apartment, confirming financial interdependence consistent with a domestic partnership.

The Supreme Court stresses that the superior court acknowledged some of this evidence — calling the joint title documents Huang’s “strongest argument” — but then failed to grapple with it meaningfully, instead:

relying disproportionately on Huang’s lack of direct financial contribution, and
crediting only the portion of Kobbeman’s testimony that he did not intend joint ownership while neglecting his statements supporting a survivorship interest for Huang.

This selective treatment of the record, the Supreme Court holds, is not consistent with the required totality‑of‑circumstances analysis and constitutes legal error.

D. Irrelevance of Relationship Length and Instability

The superior court also reasoned that Huang and Kobbeman’s relationship was relatively “short‑lived” and “tenuous” compared with domestic partnerships recognized in earlier cases, citing:

McConville (six years),
Tolan (seven years),
Wood v. Collins, 812 P.2d 951 (Alaska 1991) (twelve years),
Tomal (fourteen years), and
Bishop (thirteen years).

The Supreme Court firmly rejects the suggestion that relationship length is a valid factor in deciding whether specific property is partnership property:

None of the cited cases treat duration as an element of whether property belongs to the partnership.
Once a domestic partnership has been recognized (as here), the question is not “was the relationship long enough?” but “what did the parties intend to own together during that partnership?”

By importing duration into the classification analysis, the superior court relied on an improper factor, which further undermined its conclusion.

E. The Limited Role of “Cunning, Anticipatory Designs”

The superior court speculated that it was “not clear from the evidence” whether “cunning, anticipatory designs” were used to get Huang’s name on the deed. This language comes from Tolan, where the court was concerned about one party manipulating title to forestall a later claim by the other.

The Supreme Court notes that such concerns are largely misplaced here because:

There is no serious allegation that Huang tricked Kobbeman into putting her name on the title; rather, he requested it.
The scenario in which “cunning designs” matters is typically when a titled owner withholds the other party’s name from title for strategic reasons, not when a party voluntarily and knowingly adds the other’s name.

Thus, rather than protecting the truly intended non‑owner from a gratuitous name on the deed, the “cunning designs” concept more often protects a de facto co‑owner whose name was never put on title. Here, the logic of Tolan actually favors treating the jointly titled property as presumptively reflecting mutual intent, absent compelling contrary evidence.

F. The Remand: What the Superior Court Must Do Next

The Supreme Court does not itself conclusively declare the house to be domestic partnership property. Instead, it vacates the contrary finding and remands for:

additional fact finding consistent with the proper legal standards; and
a fresh evaluation of the parties’ intent in light of all the evidence, including the joint title documents and Kobbeman’s own statements about why Huang was added to the title.

On remand, the superior court must:

remove from its analysis the improper weight given to:
- Huang’s lack of financial contribution as a precondition to sharing ownership;
- the short and unstable nature of the relationship; and
- the misconceived application of the “cunning, anticipatory designs” notion.
expressly address the core indicia of intent, including:
- the email exchange with the loan officer;
- the marriage license application;
- the “husband and wife” designation on the deed and deed of trust;
- the parties’ explanation for putting both names on the documents; and
- their pattern of shared expenses and living arrangements.

Depending on its renewed findings, the superior court may:

classify the house as partnership property and then equitably allocate the parties’ respective interests (which need not be 50/50, particularly in light of unequal financial contributions); or
in the alternative, if it can lawfully and persuasively find that despite the joint title the parties truly intended the home to be solely Kobbeman’s during the relationship, explain that conclusion with rigorous reference to the corrected legal standards.

VI. Impact and Significance

A. Nonprecedential Yet Persuasive

The opinion is expressly designated a memorandum decision under Alaska Appellate Rule 214(d) and therefore does not create binding precedent. Nonetheless, it is likely to be cited (with the required attachments) for its persuasive value in future disputes, especially where:

engaged or cohabiting couples take joint title to property ahead of marriage;
one partner makes most or all of the financial contributions; and
a short‑lived or tumultuous relationship ends, leaving disputed expectations about property ownership.

B. Reinforcing Existing Doctrine

Rather than announcing a fundamentally new rule, Huang v. Kobbeman reinforces the trajectory of Alaska domestic partnership law:

Intent is paramount. The decision underscores that intent — not title alone, not contributions alone, not relationship length — is the central determinant in classifying property as partnership or separate property.
Financial disparity is not disqualifying. Once a domestic partnership exists, uneven financial contributions do not prevent property from being “partnership property,” though they may influence each partner’s share of that property.
Title remains strong evidence, not a mere formality. When both parties deliberately take title as co‑owners and use “husband and wife” designations, courts must seriously consider that as probative of a joint ownership intent, unless compelling contrary evidence exists.
Duration of the relationship is not a classification factor. While length may matter when determining whether a domestic partnership exists in the first place, it is not listed in Bishop and is not a legitimate factor in deciding whether specific property acquired during the partnership belongs to that partnership.

C. Practical Implications for Unmarried Couples

For unmarried couples in Alaska, the decision conveys several practical lessons:

If you take joint title to real property and hold yourselves out as spouses (even informally, such as on deeds or loan documents), courts will view that as strong evidence of mutual ownership intent, even if only one of you makes the payments.
Courts will look beyond whose name is on the mortgage checks to how you described your relationship and why you structured the transaction as you did.
If you intend property to be purely separate notwithstanding joint paperwork (for example, adding a name “for convenience” only), it is critical to:
- memorialize those intentions clearly (e.g., in a written cohabitation agreement or trust/beneficiary designation); and
- avoid document language (like “husband and wife” or “joint tenants”) that implies present joint ownership.

For practitioners and trial courts, the case is a reminder that:

domestic partnership property analysis must be fact‑rich and sensitive to the parties’ own words and choices;
the Bishop factors are guideposts, not a checklist; and
findings that ignore or selectively discount key evidence of intent are vulnerable to reversal even under the deferential “clear error” standard.

VII. Key Legal Concepts Explained

A. Domestic Partnership (Unmarried Cohabitation) in Alaska Law

A “domestic partnership” in Alaska jurisprudence is not a statutory status; it is a judicially recognized concept used to resolve property disputes between unmarried partners who behaved in a marriage‑like way. Courts look for:

shared residence and household responsibilities,
financial interdependence and joint decision‑making,
holding themselves out socially as a couple similar to spouses, and
evidence that they intended to pool certain resources or build joint assets.

Once a domestic partnership is found, courts may equitably divide domestic partnership property — property that the partners intended to own together — upon separation or dispute.

B. Domestic Partnership Property vs. Separate Property

In this context:

Domestic partnership property is property that both partners intended to acquire and hold for the benefit of the partnership, usually acquired during the partnership and often used as a family home or asset.
Separate property is property that a partner intended to keep solely for themselves, even if acquired during the relationship, such as a pre‑existing asset never integrated into shared life.

Because there is no governing statute as in divorce cases, the distinction is derived from contract principles and equity, and intent is the pivotal determinant.

C. Standards of Review: Clear Error vs. De Novo

Clear error applies to factual findings (e.g., what the parties intended, who did what, whether testimony is credible). The appellate court does not simply re‑weigh evidence; it must defer unless it is left with a “definite and firm conviction” that a mistake was made.
De novo review applies to legal conclusions and classifications (e.g., whether those facts, as found, amount to domestic partnership property under governing law). The appellate court substitutes its own judgment and owes no deference on pure legal questions.

D. “Totality of the Circumstances”

This phrase means that the court must consider all relevant facts together rather than isolating any single factor. In domestic partnership cases, that includes:

documentary evidence (titles, deeds, tax returns),
oral statements and testimony about intent,
behavioral patterns (who paid which bills, how decisions were made), and
social presentation (how the couple held themselves out to others).

No one element is necessarily controlling; the question is how all the evidence fits together to reveal the parties’ genuine understanding.

VIII. Conclusion

Huang v. Kobbeman is a nonprecedential but important memorandum opinion within Alaska’s domestic partnership jurisprudence. It does not break new doctrinal ground so much as reassert and sharpen several core principles:

Intent is central to classifying property as domestic partnership or separate property.
Financial or labor contributions, while relevant, do not operate as prerequisites to sharing ownership.
Joint title and marital‑style documentation (e.g., self‑description as “husband and wife”) are powerful indicia of joint intent that cannot be lightly discounted, particularly when one partner affirmatively requests the other’s inclusion on the title.
The length or perceived stability of the relationship is not a proper factor in deciding whether a specific asset acquired during the partnership belongs to that partnership.

By vacating the superior court’s classification of the home as solely Kobbeman’s property and requiring a renewed, comprehensive analysis of the parties’ intent, the Alaska Supreme Court reinforces that property disputes between unmarried partners must be resolved with close attention to the partners’ own actions, words, and documented choices.

For litigants, lawyers, and judges, the case underscores that even in short‑lived relationships, significant assets like homes may be treated as jointly owned if the parties, in forming a domestic partnership, acted and documented their affairs in ways consistent with a marriage‑like intent to share property.