Once law in Arizona, this rule has now been overturned and replaced by the apportionment rule. Under this rule, when separate property either generated profits or increased in value during the marriage, the Court was required to determine that such profits and increases were either all separate property or all community property. In 1979, the Arizona Supreme Court did away with this rule, favoring the more even-handed approach of the Apportionment Rule. See Cockrill v. Cockrill, 124 Ariz. 50 (1979). See also Apportionment Rule.