Does the no-reimbursement rule apply to post-separation payments out of separate property?

The applicability of the no-reimbursement rule of See v. See, supra, 64 Cal.2d 778, 51 Cal.Rptr. 888, 415 P.2d 776, to post-separation payments out of separate property was recently considered, in a related context, in In re Marriage of Smith (1978) 79 Cal.App.3d 725, 145 Cal.Rptr. 205. In Smith, husband sought reimbursement for payments which he made after separation on preexisting community debts. In considering the no-reimbursement rule of See, the court first noted that See and the cases

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