Amanda Maxine Patterson v. Edward James

Under Rule 18, W.Va. R.C.P. an action to impress a constructive trust upon property acquired through joint funds or joint efforts during coverture but titled in the name of one spouse only may be joined as an independent count in a divorce complaint, and where all of the requirements for a court of equity to declare a constructive trust exist, the court may impress a trust upon real property as part of its overall relief in a divorce proceeding.