Baughman v. Baughman

2021 Ohio 2019, 173 N.E.3d 938
CourtOhio Court of Appeals
DecidedJune 16, 2021
Docket29870
StatusPublished
Cited by1 cases

This text of 2021 Ohio 2019 (Baughman v. Baughman) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Baughman v. Baughman, 2021 Ohio 2019, 173 N.E.3d 938 (Ohio Ct. App. 2021).

Opinion

[Cite as Baughman v. Baughman, 2021-Ohio-2019.]

STATE OF OHIO ) IN THE COURT OF APPEALS )ss: NINTH JUDICIAL DISTRICT COUNTY OF SUMMIT )

CHRISTINE A. BAUGHMAN C.A. No. 29870

Appellant

v. APPEAL FROM JUDGMENT ENTERED IN THE JOSHUA R. BAUGHMAN COURT OF COMMON PLEAS COUNTY OF SUMMIT, OHIO Appellee CASE No. DR-2018-05-1364

DECISION AND JOURNAL ENTRY

Dated: June 16, 2021

HENSAL, Presiding Judge.

{¶1} Christine Baughman appeals a judgment entry of the Summit County Court of

Common Pleas, Domestic Relations Division. For the following reasons, this Court reverses.

I.

{¶2} The Baughmans married in 2006 and have not had any children together. At the

time of the marriage, Husband was a highly valued employee of a tire company, but he did not

own any stock or have an ownership interest in the company. In 2011, the tire company was

purchased by another company. Although Husband continued to work for the new company, he

received five million dollars in exchange for signing a five-year non-compete agreement, which

would begin to run upon his conclusion of employment with the new company. Husband’s

employment at the new company ended in October 2012. The parties used some of the five million

dollars to buy businesses, to buy and flip houses, and to live off during periods in which Husband

was unemployed. 2

{¶3} In May 2018, Wife filed a complaint for divorce and Husband subsequently

counterclaimed for divorce. The parties entered into a separation agreement on every issue except

for disposition of the remainder of the five million dollars. That issue was tried before a magistrate

over three separate days in 2019. In February 2020, the magistrate found that the amount was paid

to Husband in exchange for his signing of the non-compete agreement, rejecting Husband’s

argument that it was deferred bonus compensation from the original tire company. The magistrate

nevertheless found that, because the payment arose from a non-compete agreement, it was

Husband’s separate property and awarded the remaining amount entirely to him. Wife objected to

the magistrate’s decision, but the trial court overruled her objection and adopted the magistrate’s

decision. Wife has appealed, assigning two errors.

II.

ASSIGNMENT OF ERROR I

THE TRIAL COURT ERRED IN FINDING COMPENSATION PAID TO HUSBAND DURING THE MARRIAGE PURSUANT TO A NON-COMPETE AGREEMENT WAS A NON-MARITAL ASSET.

{¶4} In her first assignment of error, Wife argues that the trial court incorrectly found

that the non-compete payment was Husband’s separate property. “We review a property division

in a divorce proceeding to determine whether the trial court abused its discretion.” Stepp v. Stepp,

9th Dist. Medina No. 03CA0052-M, 2004-Ohio-1617, ¶ 10. The characterization of property as

marital or separate, however, is a question of fact that we review under a manifest weight of the

evidence standard. Ostmann v. Ostmann, 168 Ohio App.3d 59, 2006-Ohio-3617, ¶ 9 (9th Dist.).

If the parties contest whether an asset is marital or separate property, the asset is presumed to be

marital property unless it is proven otherwise. C.S. v. M.S., 9th Dist. Summit No. 29070, 2019- 3

Ohio-1876, ¶ 16. The party seeking to have the asset declared separate property has the burden of

proving that the asset is separate property. Id.

{¶5} Revised Code Section 3105.171 governs the division of marital and separate

property. Under Section 3105.171(A)(3)(a)(i), marital property includes “[a]ll real and personal

property that currently is owned by either or both of the spouses, including, but not limited to, the

retirement benefits of the spouses, and that was acquired by either or both of the spouses during

the marriage[.]” Husband acknowledges that he received the five-million-dollar payment in April

2011, which was during the marriage. He also acknowledges that he departed the new company

18 months after signing the non-compete agreement, which was October 2012. Under the terms

of the agreement, Husband agreed not to compete for five years after he left the company.

Accordingly, the agreement concluded in October 2017. Wife did not file for divorce until May

2018.

{¶6} Although the definition of marital property is broad, it “does not include any

separate property.” R.C. 3105.171(A)(3)(b). Under Section 3105.171(A)(6)(a), “[s]eparate

property” means “[a]n inheritance by one spouse * * * during the course of the marriage; * * *

[a]ny real or personal property * * * that was acquired by one spouse prior to the date of the

marriage; * * * [and] [p]assive income and appreciation acquired from separate property by one

spouse during the marriage[.]” It also includes “[a]ny real or personal property or interest in real

or personal property acquired by one spouse after a decree of legal separation[,]” “[a]ny real or

personal property or interest in real or personal property that is excluded by a valid antenuptial

agreement[,]” “[c]ompensation to a spouse for the spouse’s personal injury,” and “[a]ny gift of

any real or personal property * * * made after the date of the marriage and that is proven by clear 4

and convincing evidence to have been given to only one spouse.” The compensation Husband

received for signing the non-compete agreement does not fall into any of those categories.

{¶7} The trial court did not analyze Section 3105.171 in determining whether the non-

compete payment was marital or separate property. Instead, it determined that any proceeds of a

non-compete agreement are separate property under this Court’s decision in Blodgett v. Blodgett,

9th Dist. Summit No. 13547, 1988 WL 110926 (Oct. 19, 1988). In Blodgett, the parties married

in 1975 and around the same time Mr. Blodgett purchased a company. At some point prior to the

parties’ separation in 1986, Mr. Blodgett sold the company for several million dollars. Three

payments were at issue in the case: (1) the initial sale payment, (2) an incentive payment to Mr.

Blodgett if the net worth of the company increased by a certain amount by August 31, 1989, and

(3) a future payment to Mr. Blodgett if he did not compete with the purchaser. This Court

determined that the initial payment and incentive payment were both marital assets. Id. at * 2. It

determined that the future non-compete payment was Mr. Blodgett’s separate property, however,

because it was “solely to prevent [him] from exercising his business acumen in competition against

[purchaser].” Id. This Court noted that there was evidence that, absent the agreement, Mr. Blodgett

could start a new company that could supplant the purchaser and that the non-compete payment

was worthwhile to the buyer to protect its investment. Id.

{¶8} There are substantive differences between Blodgett and this case. First, Blodgett

predates Section 3105.171 and its definitions of marital and separate property. There are no similar

definitions discussed in Blodgett. Second, the non-compete payment had not been made by the

time of the parties’ divorce in Blodgett and remained conditional on Husband’s continued

adherence to the non-compete agreement. In this case, Husband received the payment in 2011 and

had fully completed the non-compete agreement by the time of the parties’ divorce. Blodgett, 5

therefore, is legally and factually distinguishable from this case. This case is also distinguishable

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2021 Ohio 2019, 173 N.E.3d 938, Counsel Stack Legal Research, https://law.counselstack.com/opinion/baughman-v-baughman-ohioctapp-2021.