It isn't how the title on the account is...it is how and when the funds were acquired.
So if the funds were acquired in his account from his earnings during the marriage, then those funds are marital property. If they are from gift or inheritance during the marriage to just him OR from his earning pre marriage, then they are just his.
If the woman has put her child support in an account in her own name, then arguably - no clear cut straight answer - the funds are just hers because they are not income but rather support for the children. On the flip side,
if she saved those dollars and instead used money earned during the marriage to support those kids from her prior marriage then the husband may have a claim to some of those funds.
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