BADWAL v. BADWAL (Appellate Division, 2nd Dep’t)

The Court affirmed the Supreme Court’s decision not to award any equitable distribution to the husband from the wife’s enhanced earnings due to her nursing license obtained during the marriage.  There was no evidence that the husband made any substantial contributions to the wife’s acquisition of her nursing license; he made no career sacrifices and did not assume a disproportionate share of housework as a consequence of the wife’s educational endeavors.  His “modest contributions” indicate that the attainment of the nursing license was “directly the result of the [wife’s] own ability, tenacity, perseverance, and hard work and therefore, the Court was allowed to preclude the husband from sharing in any enhancements.