to be community property. After conducting a choice-of-law analysis, id. at 505-06, 286 Cal.Rptr. 714, the California Court of Appeal rejected the husband’s claim, based on its conclusion "that California, and not Nevada [where the property was located], is the state which has the most significant relationship to the parties and issues in this case.” Id. at 506, 286 Cal.Rptr. 714. The dispute in the present case involves a claim by a California-based third-party creditor, on property located in California, giving California an interest in the application of its law. 3 . Other community property jurisdictions with statutes similar to A.R.S. § 25-214 also recognize that estoppel principles may apply. See, e.g., Miller v. Johnston, 270 Cal.App.2d 289, 300 n.6, 75 Cal.Rptr. 699 (1969) (<HOLDING>); Colo. Nat’l Bank of Denver v. Merlino, 35
holding that a spouse was bound by a conveyance of community property to which she was not a party because of her knowledge and acquiescence to the conveyance holding in forfeiture case that circumstances surrounding mothers conveyance of stock to her soninlaw were sufficient under wisconsin law to create constructive trust in stock in daughters favor where testimony showed such was intent of conveyance despite facts that stock registered in husbands name and that no documentation supported testimony holding justice court did not have jurisdiction to adjudicate merits of title because it was required to analyze conveyance of property against claim of homestead right holding that the transfer of stock in an insolvent corporation did not constitute fair consideration to support conveyance of property to its stockholder holding that transfer of property to llc involved no consideration for state conveyance tax purposes because it was a unilateral act and not the result of a bargainedfor exchange