E.A. v. A.A.

2025 Ohio 4583
CourtOhio Court of Appeals
DecidedOctober 2, 2025
Docket113654
StatusPublished

This text of 2025 Ohio 4583 (E.A. v. A.A.) 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
E.A. v. A.A., 2025 Ohio 4583 (Ohio Ct. App. 2025).

Opinion

[Cite as E.A. v. A.A., 2025-Ohio-4583.]

COURT OF APPEALS OF OHIO

EIGHTH APPELLATE DISTRICT COUNTY OF CUYAHOGA

E.A., :

Plaintiff-Appellee/ Cross-Appellant, : No. 113654 v. :

A.A., :

Defendant-Appellant/ Cross-Appellee. :

JOURNAL ENTRY AND OPINION

JUDGMENT: AFFIRMED IN PART, REVERSED IN PART, AND REMANDED RELEASED AND JOURNALIZED: October 2, 2025

Civil Appeal from the Cuyahoga County Court of Domestic Relations Case No. DR-21-384289

Appearances:

Stafford Law Co., L.P.A., Joseph G. Stafford, Nicole A. Cruz, and Kelley R. Tauring, for appellee/cross- appellant.

Rosenthal │ Lane, L.L.C., Scott S. Rosenthal, James L. Lane, and Alarra S. Jordan, for appellant/cross-appellee.

SUTTON, Judge

Appellant/Cross-Appellee A.A. and Appellee/Cross-Appellant E.A.

appeal the judgment of the Cuyahoga County Court of Common Pleas, Domestic Relations Division. For the reasons that follow, this Court affirms in part and

reverses in part.

Relevant Background Information

On February 25, 2021, E.A. filed a complaint for divorce in the

Cuyahoga County Court of Common Pleas, Domestic Relations Division. The parties

have one minor child.

After a lengthy trial that occurred on numerous days over the course

of more than a year in front of one magistrate and two judges, the trial court granted

the parties a divorce on January 19, 2024, and issued a judgment entry dividing the

property, ordering spousal and child support, ordering A.A. to pay $150,000.00 of

E.A.’s attorney fees, and ordering A.A. to pay the fees of the guardian ad litem

(“GAL”).

Both A.A. and E.A. have appealed the decision of the trial court. A.A.

raises nine assignments of error and E.A. raises four assignments of error for our

review. To facilitate our analysis, we have addressed the assignments of error out of

order and have grouped some of the assignments of error together.

A.A.’s Assignment of Error III (Date of Marriage)

The trial court erred and abused its discretion in finding that the date of marriage was June 27, 2014.

A.A. argues in his third assignment of error the trial court erred and

abused its discretion in finding the parties’ date of marriage was June 27, 2014

instead of June 27, 2016, for purposes of determining marital and separate property. E.A. responds the trial court properly exercised its discretion in using June 27, 2014,

the date of their religious ceremony, as the date the marriage commenced. Before

the trial court can divide property between the parties in a divorce, it must first

determine what property is marital and what property is separate. The date of

marriage is necessary to this determination.

R.C. 3105.171(B) provides in relevant part:

In divorce proceedings, the court shall . . . determine what constitutes marital property and what constitutes separate property. In either case, upon making such a determination, the court shall divide the marital and separate property equitably between the spouses, in accordance with this section. For purposes of this section, the court has jurisdiction over all property, excluding the social security benefits of a spouse other than as set forth in division (F)(9) of this section, in which one or both spouses have an interest.

Marital property is property currently owned by either or both

spouses that was acquired “during the marriage,” which includes real and personal

property as well as income and appreciation on separate property due to the labor,

monetary or in-kind contribution of either or both spouses that occurred during the

marriage. R.C. 3105.171(A)(3). R.C. 3105.171(A)(2)(a) defines “during the marriage”

as “the period of time from the date of the marriage through the date of the final

hearing in an action for divorce or in an action for legal separation[.]” However, if

the trial court determines the date of the marriage would be inequitable, it may

select a date it considers equitable. R.C. 3105.171(A)(2)(b) provides:

If the court determines that the use of either or both of the dates specified in division (A)(2)(a) of this section would be inequitable, the court may select dates that it considers equitable in determining marital property. If the court selects dates that it considers equitable in determining marital property, “during the marriage” means the period of time between those dates selected and specified by the court.

The trial court found the parties entered into a religious marriage on

June 27, 2014, and a “subsequent civil ceremony” on June 27, 2016, and further

found “that it would be inequitable to use June 27, 2016” when determining the

duration of marriage, citing R.C. 3105.171(A)(2)(b). To avoid confusion, this Court

will refer to the 2014 date as the parties’ “religious marriage” and the 2016 date as

the “civil marriage.”

Generally, this Court reviews the trial court’s determination pursuant

to R.C. 3105.171(A)(2)(b) regarding the period constituting “during the marriage”

for an abuse of discretion. Allan v. Allan, 2019-Ohio-2111, ¶ 85 (8th Dist.). A trial

court abuses its discretion when its decision is “unreasonable, arbitrary[,] or

unconscionable.” Blakemore v. Blakemore, 5 Ohio St.3d 217, 219 (1983). When

applying the abuse of discretion standard, a reviewing court is precluded from

simply substituting its own judgment for that of the trial court. Pons v. Ohio State

Med. Bd., 66 Ohio St.3d 619, 621 (1993).

We have stated: “R.C. 3105.171(A)(2)(b) provides the court with

jurisdiction to select a date other than the [date of the civil marriage] for purposes

of equitably determining what comprises the marital estate for a division of property

assessment,” D’Hue v. D’Hue, 2002-Ohio-5857, ¶ 48 (8th Dist.) “In order to achieve

an equitable distribution of property, the trial court must be allowed to use

alternative valuation dates where reasonable under the particular facts and circumstances of the case.” Id. at ¶ 89, citing Langer v. Langer, 123 Ohio App.3d

348 (2d Dist. 1997. “The trial court has broad discretion to determine what is

equitable upon the facts and circumstances of each case.” Al-Mubarak v. Chraibi,

2015-Ohio-1018, ¶ 32 (8th Dist.), citing Kunkle v. Kunkle, 51 Ohio St.3d 64 87

(1990).

The trial court found the following facts when determining that June

27, 2014, was the date of the parties’ marriage for purposes of calculating the

duration of the marriage and division of marital property. The parties entered into

a religious marriage on June 27, 2014; the parties lived together prior to the religious

ceremony and continued to live together after the religious ceremony; the parties

referred to each other as husband and wife after the religious ceremony, at least in

A.A.’s community; E.A. wore a ring after the 2014 religious ceremony; E.A. became

pregnant in 2016 and the child was born in November, after the parties June 27,

2016 civil ceremony. A.A. acquired several residential properties prior to the civil

marriage but after the religious marriage.

In addition, E.A. testified she was fully dependent on A.A. from 2014.

A.A. testified the parties started living together in 2013 and E.A. was financially

dependent on him, stating, “[s]he was dependent on me the first day she met me.”

The record further reflects that E.A., A.A., and the parties’ minor child resided in

one of the properties purchased by A.A. prior to the parties’ civil marriage. A.A. also

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2025 Ohio 4583, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ea-v-aa-ohioctapp-2025.