E.B. v. R.N.

2024 Ohio 1455
CourtOhio Court of Appeals
DecidedApril 17, 2024
Docket30199
StatusPublished

This text of 2024 Ohio 1455 (E.B. v. R.N.) 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.B. v. R.N., 2024 Ohio 1455 (Ohio Ct. App. 2024).

Opinion

[Cite as E.B. v. R.N., 2024-Ohio-1455.]

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

E.B. (nee) N. C.A. No. 30199

Appellant

v. APPEAL FROM JUDGMENT ENTERED IN THE R.N. COURT OF COMMON PLEAS COUNTY OF SUMMIT, OHIO Appellee CASE No. DR-2019-01-0077

DECISION AND JOURNAL ENTRY

Dated: April 17, 2024

CARR, Judge.

{¶1} Defendant-Appellant E.B. (“Wife”) appeals the judgment of the Summit County

Court of Common Pleas, Domestic Relations Division. This Court reverses and remands the

matter for proceedings consistent with this decision.

I.

{¶2} Wife and Plaintiff-Appellee R.N. (“Husband”) were married on August 21, 2016.

At the time of the marriage, Husband was 39 years old, and Wife was 33 years old. Wife is an

attorney and Husband is a business owner. After being unable to conceive children, the parties

sought the help of a fertility specialist and tried artificial insemination. When that was ultimately

unsuccessful, in June 2018, the couple went to another doctor and opted to try invitro fertilization

(“IVF”). In so doing, in August 2018, the couple signed a document titled “Disposition of

Embryos” and subtitled “Declaration of Intent[.]” The document provided information and options

to the couple concerning what the couple would like done with the embryos in the event of 2

separation, divorce, death, etc. The first round of IVF produced 4 embryos; 2 were determined to

be normal and 2 were considered abnormal. The second round of IVF produced 10 embryos; nine

were determined to be normal and one was considered abnormal. The embryos were not implanted

in Wife and were frozen.

{¶3} In January 2019, Husband filed a complaint for divorce and Wife filed a

counterclaim for divorce in July 2019. In December 2019, Wife was diagnosed with thyroid

cancer. Wife underwent surgery to remove her thyroid gland and then received radioactive iodine

in March 2020. Wife was informed that she should not become pregnant for 12 months following

her radiation treatment.

{¶4} The matter proceeded to a trial before a magistrate in early 2021. However,

following the trial, the magistrate left employment with the trial court and a new judge was

assigned to the case. At that time, the matter was assigned to a visiting judge. The visiting judge

opted to rehear the matter. Trial was set to take place in the beginning of October 2021. During

the first hearing date, the trial court was informed that the parties reached an agreement with

respect to all matters aside from the disposition of the frozen embryos. After receiving information

related to the parties’ agreement, the trial court recessed until October 29, 2021, at which point

testimony pertaining to the disposition of the frozen embryos was heard.

{¶5} On November 17, 2021, a decree of divorce was filed. The trial court determined

that frozen embryos were marital property, subject to distribution by the trial court. The trial court

acknowledged that the parties’ desires for the frozen embryos were at odds: Wife wanted the

frozen embryos awarded to her so that she could use them to become pregnant and Husband was

adamant that he wanted to be disentangled from Wife and wanted the frozen embryos to be donated

to another couple to be used to achieve a pregnancy. Based upon the language of the document, 3

the testimony of the parties, and the paucity of available law, the trial court awarded 7 frozen

embryos to Wife and 7 to Husband with the requirement that all of the frozen embryos be given to

the clinic for donation for another couple to use to achieve a pregnancy.

{¶6} Wife has appealed, raising a single assignment of error for our review.

II.

ASSIGNMENT OF ERROR

THE TRIAL COURT ERRED AS A MATTER OF LAW IN MISCONSTRUING A STANDARD FORM “DECLARATION OF INTENT” CONTRACT CREATED BY THE FERTILITY CLINIC AS EXPRESSING THE MUTUAL INTENT AND AGREEMENT OF THE PARTIES WITHOUT ANALYZING AND PROPERLY BALANCING THE PARTIES’ INTERESTS IN DETERMINING THE APPROPRIATE DISPOSITION OF THE FOURTEEN PRE-EMBRYOS CREATED THROUGH THE IVF PROCESS SHORTLY BEFORE THE HUSBAND FILED FOR DIVORCE.

{¶7} Wife argues in her sole assignment of error that the trial court erred in applying the

contractual approach to the disposition of the frozen embryos as opposed to the balancing

approach. Wife argues the Contract was ambiguous as she believed Husband was consenting to

Wife receiving the frozen embryos to become pregnant herself and Husband believed he did not

consent to doing so. Because of this alleged ambiguity, Wife argues that her and Husband’s

interests should have been balanced by the trial court. In addition, Wife asserts that categorizing

the frozen embryos as marital property is inadequate as they have the potential to develop into

children. Because this Court concludes that the trial court’s approach was inconsistent with the

nature of the frozen embryos and overarching principles of Ohio law, we agree the trial court

abused its discretion.

{¶8} Three main approaches to determining the disposition of frozen embryos in the

context of divorce have been recognized: (1) the contractual method; (2) contemporaneous-

mutual-consent method; and (3) the balancing method. See Kotkowski-Paul v. Paul, 11th Dist. 4

Portage No. 2021-P-0088, 2022-Ohio-4567, ¶ 50. “Under the contractual approach, a court

considers a contract between the parties and the clinic with which they were treated during the IVF

process. If the contract is valid and enforceable, the inquiry ends and the contractual provisions

govern. This approach is embraced by the majority of jurisdictions that have addressed the issue.”

Id. at ¶ 51. At least two courts in Ohio have previously adopted this approach. See Cwik v. Cwik,

1st Dist. Hamilton No. C-090843, 2011-Ohio-463, ¶ 56-65; Karmasu v. Karmasu, 5th Dist. Stark

No. 2008 CA 00231, 2009-Ohio-5252, ¶ 25-29. “Under the contemporaneous-mutual-consent

approach, the frozen embryos must remain in storage until the parties reach an agreement regarding

disposition.” Kotkowski-Paul at ¶ 52. “[W]here no agreement exists or * * * [is] deemed

controlling, courts use the third approach, which balances the parties’ competing interests.” Id. at

¶ 53. The Eleventh District in Kotkowski-Paul concluded that the trial court there appropriately

applied the balancing approach under circumstances where there was an executed contract, but it

was not produced by the parties and the parties could not agree to the allocation of the frozen

embryos. Id. at ¶ 55.

{¶9} Unfortunately, all of these approaches are inadequate in one way or another, and

there is a dearth of statutory law in Ohio in this area to make up for these inadequacies; a problem

that must be rectified by action by the legislature.

{¶10} First, and foremost, the approaches do not account for the fact that what is involved

is not property, but life or the potential for life. The frozen embryos are life in one of its earliest

stages of development; the cells are human, alive, and capable of developing into a child. See

Black’s Law Dictionary (11th ed.2019) (defining “embryo” as “[a] developing but unborn or

unhatched animal; esp., an unborn human from conception until the development of organs[.]”).

Because this Court cannot conclude that the frozen embryos are property, we likewise cannot say 5

that they are martial property as that term has been defined in the revised code.

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2024 Ohio 1455, Counsel Stack Legal Research, https://law.counselstack.com/opinion/eb-v-rn-ohioctapp-2024.