For years most Florida courts have found that passive appreciation of a nonmarital home is not a marital asset subject to equitable distribution. It used to be that when the mortgage on a non-marital home was paid from marital funds, only the decrease in the mortgage principle was treated as a marital asset and split at the divorce. Those days are gone - both the passive appreciation days and the days of only splitting the mortgage pay-down.
In Kaaa v. Kaaa, the Florida Supreme Court declared that when marital funds paid down a mortgage on a nonmarital home, the passive appreciation of the home is a marital asset subject to equitable distribution. This is a big change, unless you are in the 1st District Court of Appeals area in the Panhandle. Read the case carefully - it changes property distribution in Florida divorces.