In the last decade, courts have taken a much more conservative approach when it comes to awarding a spouse a portion of the value of a professional license or degree earned by the other spouse during the marriage. Courts are demanding to know exactly what kind of assistance a spouse provided to aid the other spouse in acquiring his or her degree, and whether this assistance was so significant or unique as to warrant awarding a distributive share.

First, a spouse must establish that he or she made a substantial contribution to the acquisition of the degree or license. But even when a spouse maintains that he or she was the family's primary wage earner and cared for their children while the other spouse attended school, courts have ruled that these sacrifices merely represent overall contributions to the marriage rather than an additional effort to support the spouse in obtaining his or her license.