Cochran v. Cochran

2025 Ohio 2565
CourtOhio Court of Appeals
DecidedJuly 18, 2025
Docket24CA21
StatusPublished
Cited by1 cases

This text of 2025 Ohio 2565 (Cochran v. Cochran) 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
Cochran v. Cochran, 2025 Ohio 2565 (Ohio Ct. App. 2025).

Opinion

[Cite as Cochran v. Cochran, 2025-Ohio-2565.]

IN THE COURT OF APPEALS OF OHIO FOURTH APPELLATE DISTRICT ATHENS COUNTY

Tonya J. Cochran, : Case No. 24CA21

Plaintiff-Appellant, :

v. : DECISION AND JUDGMENT ENTRY David M. Cochran, :

Defendant-Appellee. : RELEASED 7/18/2025 ______________________________________________________________________ APPEARANCES:

Tonya J. Cochran, Glouster, Ohio, pro se.

K. Robert Toy, Athens, Ohio, for appellee. ______________________________________________________________________ Hess, J.

{¶1} Tonya J. Cochran appeals from the final divorce decree issued by the

Athens County Common Pleas Court, Domestic Relations Division. Tonya contends that

the trial court erred when it failed to determine the date of termination of the marriage, the

duration of the marriage, and a consistent date for valuation of property. She also

contends that the trial court erred in finding that a business entity was a separate asset

owned by her husband, David M. Cochran. Last, she contends that the trial court erred

by issuing a distributive award related to the marital residence.

{¶2} We find that the trial court failed to specify the dates it used to determine

the beginning and ending of the marriage and make other required statutory findings.

Thus, we cannot engage in meaningful review of the trial court’s division of martial and

separate property or the sum of the distributive award. We sustain the assignments of Athens No. 24CA21 2

error, reverse the judgment, and remand the cause for further action consistent with this

judgment.

I. FACTS AND PROCEDURAL HISTORY

{¶3} On April 19, 2022, Tonya filed a complaint for divorce from David. She

alleged that the couple married on July 4, 2013 and had no children born of the marriage.

Tonya alleged that the business known as Matt Cochran Trucking, LLC was a business

in possession and control of marital property, and she requested that she be awarded a

divorce decree and an equitable division of all assets and liabilities. David answered and

denied that Matt Cochran Trucking was in possession and control of marital property. The

matter proceeded to a final divorce hearing on June 20, 2024.

{¶4} Tonya represented herself at the final hearing1 and testified that David had

possession of all the business assets owned by Matt Cochran Trucking and that he has

certain marital property that included items such as lawnmowers, weed eaters,

generators, power washers, motorcycles, an RV and camping equipment, and

decorations. Tonya was residing in the marital home during the divorce proceedings,

which was a trailer that had additional rooms constructed onto it and was on land that

was owned by a third party. The trailer portion of the residence was transportable. Tonya

testified that during a hearing in a separate lawsuit in April 2023, David stated that he did

not want the home and that it was not worth moving. Therefore, when she received an

eviction notice from the landowner, she removed her personal property from the home,

but also all the cabinetry that had been installed in the house and put it in storage. Tonya

testified that the very next day after she received the eviction notice the home was

1 Tonya had been represented by two different attorneys at different times throughout the course of the

proceedings, but both attorneys requested and were granted permission to withdrawal as counsel. Athens No. 24CA21 3

burglarized and David’s guns and certain other of his possessions were stolen from the

home.

{¶5} On cross-examination, Tonya reviewed an itemized list of assets, identified

as Exhibit 1. The list itemized property that was in Tonya’s possession and property that

was in David’s possession (such as the lawnmowers and weed eaters she had previously

testified about). Tonya denied having possession of certain items on the list but admitted

she had possession of other items. She also disputed some of the valuation figures for

the assets and gave her opinion of the values. Tonya conceded that in addition to

removing the home’s cabinetry, she removed a bathroom vanity and mirror and had them

installed in her new home. Tonya also conceded that many of the items she removed

were marital property. She estimated that she had approximately $5,000 in her retirement

account, though she agreed that, based on the paystub introduced as Exhibit 2 during

her cross-examination, she had $137.67 deposited into her account every two weeks for

approximately three years (which would total approximately $10,700 in retirement

savings).

{¶6} Following her cross-examination testimony, Tonya rested her case and did

not submit any exhibits for admission into evidence.

{¶7} David testified that he had been in the family trucking business his entire

life and had also worked in the coal mining industry. David’s trucking business before he

married Tonya was called Legend Trucking. Before he married Tonya, he was living in a

trailer he purchased that was on his father’s land. After his father died, his uncle owned

the property but then lost it and it was now owned by a third party. David remodeled and

added on to the trailer after he married Tonya but admitted that the construction he did to Athens No. 24CA21 4

his trailer was on land that he did not own, which turned out to be a bad idea. As a result,

the landowner eventually evicted them from the property. David testified that the trailer

portion of the home was valued by a court at $16,074 in a separate legal proceeding.

{¶8} David testified that Tonya had sole possession of the home after she filed

for divorce and that she destroyed it while it was in her possession. She left meat in the

freezer that thawed and leaked out onto the floors and created an extremely offensive

odor. She also removed all the cabinets and faucets. She left bags of trash piled

everywhere and the entire place was ransacked. David testified that he would like a court

order for a distributive award of $51,031.96, which was the value of the custom cabinetry

Tonya removed. David would have liked to have moved the trailer portion of the home,

which was his separate property, to other land, but he obtained an estimate to do that

and, after what Tonya did to it during her occupancy, it would not be worth it to clean, try

to remove the odor, and move it.

{¶9} David also testified about the itemized list of property on Exhibit 1 and gave

his valuation of the items. David testified that he believed Tonya had the rifle his father

purchased for him as a Christmas gift and wanted her to return it. David testified that he

prepared best estimates for the value of the items on Exhibit 1.

{¶10} David testified about his trucking business. He started the trucking business

in 2008 and never comingled personal or marital funds with the trucking business. Exhibit

1 also contained a list of the trucking business’s assets and debts, and David testified

about the value of each individual asset and the size of the loans and debts. David

testified that he did not use marital assets to make any payments on the company loans

or debts and Tonya did not assist him with payments. David testified that the value of his Athens No. 24CA21 5

business debts outweighed the value of the assets. He also testified that the value of the

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Bluebook (online)
2025 Ohio 2565, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cochran-v-cochran-ohioctapp-2025.