This is an interesting article contrasting the two very different family law jurisdictions and how they compare.

Some key differences: Californians have no-fault divorce, child support is calculated very precisely by a piece of software and the division of property is far less generous to the financially weaker party: property acquired during the marriage is joint but other than that, you get out what you put in. Judges have far more discretion and needs play a greater role in England and Wales.

Overall I believe that Californian Judges adopt a far more formulaic, one-size-fits-all approach, whereas the English system, for all its faults, is a far fairer and more flexible system.

Rule Britannia!