Devito v. Devito

2024 Ohio 2234, 246 N.E.3d 992
CourtOhio Court of Appeals
DecidedJune 12, 2024
DocketC-230539
StatusPublished
Cited by1 cases

This text of 2024 Ohio 2234 (Devito v. Devito) 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
Devito v. Devito, 2024 Ohio 2234, 246 N.E.3d 992 (Ohio Ct. App. 2024).

Opinion

[Cite as Devito v. Devito, 2024-Ohio-2234.] IN THE COURT OF APPEALS FIRST APPELLATE DISTRICT OF OHIO HAMILTON COUNTY, OHIO

ELIZABETH A. CROSS DEVITO, : APPEAL NO. C-230539 TRIAL NO. DR1901095 Plaintiff-Appellee, :

vs. : O P I N I O N.

RICHARD DEVITO, :

Defendant-Appellant. :

Appeal From: Hamilton County Court of Common Pleas, Domestic Relations Division

Judgment Appealed From Is: Affirmed

Date of Judgment Entry on Appeal: June 12, 2024

Ferris & Manter and Aaron J. Manter, for Plaintiff-Appellee,

Strauss Troy Co., L.P.A., and Carrie R. Waide, for Defendant-Appellant. OHIO FIRST DISTRICT COURT OF APPEALS

WINKLER, Judge.

{¶1} Defendant-appellant Richard Devito (“Husband”) appeals the

decision of the Hamilton County Court of Common Pleas, Domestic Relations

Division, that awarded his separate property to plaintiff-appellee Elizabeth A. Cross

Devito (“Wife”) as a distributive award. We find no merit in his two assignments of

error, and we affirm the trial court’s judgment.

Factual Background

{¶2} Husband and Wife were married in 2014, and had one child. The

record shows that in 2016, Husband was arrested and jailed for producing child

pornography. Two years later, he pleaded guilty to one count of that offense and was

sentenced to 360 months (30 years) in a federal prison.

{¶3} Subsequently, Wife filed for divorce. In 2021, a magistrate conducted

a hearing to determine the property division and parental rights. In her decision,

the magistrate stated that the division of property was not equal, although it was

equitable, because due to Husband’s imprisonment, he would not be “in a position

to maintain employment, earn income or help support” the parties’ child. The

magistrate also found that Wife was entitled to a distributive award due to

Husband’s criminal actions that resulted in him being imprisoned for 30 years.

Though not specifically stated, the language of the magistrate’s decision implied that

the distributive award was justified to compensate Wife for Husband’s financial

misconduct. See Devito v. Devito, 1st Dist. Hamilton No. C-210523, 2022-Ohio-

2563, ¶ 29.

{¶4} While the magistrate found that Husband had insufficient income to

support their child, he had other assets, including his retirement accounts. The

2 OHIO FIRST DISTRICT COURT OF APPEALS

magistrate determined that Husband had two retirement accounts and awarded

Wife “the entirety of the retirement plans and investment accounts, including any

separate property portion, free and clear of any claim of [Husband].”

{¶5} Both parties objected to the magistrate’s decision. As to the property

division, the trial court overruled Husband’s objections. Wife objected on the basis

that the magistrate had failed to dispose of a 401(K) plan in Husband’s name. The

court sustained Wife’s objection and awarded her “the entirety of the retirement plan

free and clear of any claim of [Husband].” The trial court adopted the magistrate’s

decision as modified, which was incorporated into the divorce decree.

The Prior Appeal

{¶6} Husband appealed from the decree to this court. In one of his

assignments of error, he contended that the trial court abused its discretion in

awarding his separate property to Wife as a distributive award. In Devito, 1st Dist.

Hamilton No. C-210523, 2022-Ohio-2563, we reversed the trial court’s decision as

to the property division and the distributive award.

{¶7} First, we noted that the decree did not include Husband’s money from

an inheritance in the decree. We determined that it was Husband’s separate

property. Id. at ¶ 25. Then, we determined that, because the trial court’s finding

under R.C. 3105.171(E)(4) was improper and the trial court did not make any other

findings to support the distributive award, the distributive award to Wife did not

comport with the statutory requirements set forth in R.C. 3105.171. Id. at ¶ 36. We

stated that “a distributive award may be justified under R.C. 3105.171. But as

currently written, the decision does not comport with the statutory requirements.”

3 OHIO FIRST DISTRICT COURT OF APPEALS

Id. We remanded the cause to the trial court “to reconsider the division of assets and

properly determine whether a distributive award is appropriate.” Id. at ¶ 37.

The Remand

{¶8} On remand, the trial court held a hearing where counsel presented

additional oral arguments. Wife argued that Husband’s criminal activity “is the

wrongdoing that resulted in a sentence of 360 months of incarceration.” She added,

[Husband’s] wrongdoing caused his incarceration which, in turn,

interferes with his spouse’s property rights because [Wife] is now

required to use 100% of her property rights, without ongoing financial

assistance from [Husband], to incur all of the expenses associated with

raising their child which is a loss to [Wife] caused by the offending

spouse’s misconduct. Meanwhile [Husband] profits from his

wrongdoing because he is not required to pay child support for their

child due to his incarceration.

The magistrate found Wife’s argument to be persuasive. She stated that “[W]ife has

satisfied the elements for demonstrating financial misconduct,” and that financial

misconduct justified a distributive award of Husband’s separate property to Wife.

{¶9} Both parties filed objections to the magistrate’s decision. The trial

court sustained one of Wife’s objections relating to the value of Husband’s separate

property and overruled her other two objections. Husband’s objection stated that

the magistrate erred “in making a distributive award of [Husband’s] separate

property, and failed to allocate the marital property equitably.” The trial court

overruled his objection and adopted the magistrate’s decision. It added that “the

Court finds that the Magistrate did equitably divide the marital property under R.C.

4 OHIO FIRST DISTRICT COURT OF APPEALS

3105.171(F) as she thoroughly considered all of the required factors when issuing her

decision.”

{¶10} The trial court’s decision was incorporated in an amended divorce

decree, journalized on September 15, 2023. Husband now appeals from that final

order. He presents two assignments of error for review.

The Current Appeal

{¶11} In his first assignment of error, Husband contends that the trial court

erred in finding that Husband had engaged in financial misconduct and in awarding

Husband’s separate property to Wife as a distributive award. In his second

assignment of error, Husband contends that the trial court failed to allocate the

parties’ marital property equitably. He argues that the court failed to equitably

divide one of his retirement accounts because only a percentage of the funds in the

account were marital, and the rest was his separate property. The court awarded all

of the proceeds from that account to Wife as part of the distributive award. These

assignments of error are not well taken.

{¶12} We review a domestic relations court’s property division in a divorce

proceeding for an abuse of discretion. Dunn v. Dunn, 1st Dist. Hamilton Nos. C-

010282 and C-010292, 2002-Ohio-6247, ¶ 12, citing Cherry v. Cherry, 66 Ohio

St.2d 348, 421 N.E.2d 1293 (1981). R.C. 3105.171 governs the division of property in

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Bluebook (online)
2024 Ohio 2234, 246 N.E.3d 992, Counsel Stack Legal Research, https://law.counselstack.com/opinion/devito-v-devito-ohioctapp-2024.