Heffelfinger v. Heffelfinger

Ohio Court of Appeals·Decided July 20, 2026·No. 25-COA-033·Published

Opinion

IN THE OHIO COURT OF APPEALS FIFTH APPELLATE DISTRICT

ASHLAND COUNTY, OHIO

PHYLLIS M. HEFFELFINGER Case No. 25-COA-033 Plaintiff - Appellant Opinion And Judgment Entry

-vs- Appeal from the Court of Common Pleas, Domestic Relations Division, Case No. 23-DIV-

DOUGLAS K. HEFFELFINGER 037

Defendant - Appellee Judgment: Affirmed Date of Judgment Entry: July 20, 2026

BEFORE: Andrew J. King; William B. Hoffman; Robert G. Montgomery, Judges

APPEARANCES: JAMES M. RICHARD, for Plaintiff-Appellant; TODD E. CHEEK, for Defendant-Appellee.

King, P.J.

{¶ 1} Plaintiff-Appellant, Phyllis M. Heffelfinger ("Wife"), appeals the October 28, 2025 judgment entry – decree of divorce of the Ashland County Domestic Relations Court, dividing property belonging to her and Defendant-Appellee, Douglas K. Heffelfinger ("Husband"). We affirm the trial court.

FACTS AND PROCEDURAL HISTORY

{¶ 2} Husband and Wife were married on August 2, 1992. Throughout the marriage, Wife was employed as a flight attendant; Husband worked 60-70 hours per week for his parents on the family farm from the date of the marriage until 2009 when he became self- employed. The parties lived on the family farm so they did not pay rent, utilities, or a mortgage.

{¶ 3} On April 18, 2023, Wife filed a complaint for divorce. A trial before a magistrate was held on September 24-27, and October 23, 2024. By a lengthy decision filed January 29, 2025, the magistrate granted the parties a divorce and divided their property. Wife filed objections. By judgment entry filed August 13, 2025, the trial court adopted the magistrate's decision with modifications. A lengthy final judgment entry – decree of divorce was filed on October 28, 2025.

{¶ 4} Wife filed an appeal with the following assignments of error:

I

{¶ 5} "A. THE TRIAL COURT'S DECISION FINDING THAT THE INCREASE IN VALUE, OR EQUITY, OF THE FARM REAL ESTATE DURING THE MARRIAGE OF $7,462,500, PLUS THE INCREASE IN VALUE, OR EQUITY, OF THE MERCHANTABLE TIMBER DURING THE MARRIAGE OF $472,835.48, WAS NOT DUE TO THE COMBINED LABOR, MONEY, AND IN-KIND CONTRIBUTIONS OF APPELLANT (PHYLLIS) AND APPELLEE (DOUGLAS) DURING THE MARRIAGE IS CONTRARY TO LAW."

{¶ 6} "B. IN THE ALTERNATIVE, THE TRIAL COURT'S DECISION FINDING THE INCREASE IN VALUE OR EQUITY OF THE FARM REAL ESTATE, INCLUDING THE MERCHANTABLE TIMBER, WAS PASSIVE IS AGAINST THE MANIFEST WEIGHT OF THE EVIDENCE. APPELLEE (DOUGLAS) HAD THE BURDEN OF PROVING THAT THE INCREASE IN VALUE WAS PASSIVE, AND DOUGLAS FAILED TO SUSTAIN HIS BURDEN OF PROOF."

II

{¶ 7} "A. THE TRIAL COURT'S DECISION FINDING THAT THE LIFE INSURANCE DEATH BENEFITS PAID DURING THE MARRIAGE FROM THE IRREVOCABLE LIFE INSURANCE TRUSTS, WHICH REMAINED IN VARIOUS BANK ACCOUNTS AND INVESTMENT ACCOUNTS OR WERE TRACED TO SPECIFIC ASSETS AT THE TIME OF TRIAL, ARE THE SEPARATE ASSETS OF APPELLEE (DOUGLAS) IS CONTRARY TO LAW."

{¶ 8} "B. IN THE ALTERNATIVE, THE TRIAL COURT'S DECISION AWARDING APPELLEE (DOUGLAS) THE BANK ACCOUNTS, INVESTMENT ACCOUNTS, AND ASSETS FUNDED BY THE LIFE INSURANCE DEATH BENEFITS IN THE SUM OF $986,165.29 IS AGAINST THE MANIFEST WEIGHT OF THE EVIDENCE."

III

{¶ 9} "A. THE TRIAL COURT'S DECISION FINDING THAT THE 50% SHARE OF THE CROPS IN THE FIELDS THAT WERE READY FOR HARVEST AT THE TIME OF TRIAL WAS LIMITED TO 50% OF THE NET PROFIT OF THOSE CROPS, AFTER DEDUCTING THE COST OF GROWING THE CROPS, IS CONTRARY TO LAW."

{¶ 10} "B. IN THE ALTERNATIVE, THE TRIAL COURT'S DECISION ORDERING AN ACCOUNTING AND LIMITING THE 50% SHARE OF THE VALUE OF THE CROPS IN THE FIELDS AT THE TIME OF TRIAL TO THE NET PROFIT DERIVED FROM THE SALE OF THOSE CROPS, AFTER DEDUCTING THE COST OF GROWING THE CROPS, IS AGAINST THE MANIFEST WEIGHT OF THE

EVIDENCE. ALL CROP EXPENSES FOR THE 2024 CROPS WERE PREPAID PRIOR TO THE TIME OF TRIAL AND ALL THAT REMAINED WAS THE HARVEST OF THE CROPS WITH A STIPULATED VALUE OF $338,839.97."

APPLICABLE LAW

{¶ 11} In divorce proceedings, a trial court "shall divide the marital and separate property equitably between the spouses" in accordance with R.C. 3105.171(B). The trial court shall "determine what constitutes marital property and what constitutes separate property." Id. Marital property includes all "real and personal property that currently is owned by either or both of the spouses" and can include "all income and appreciation on separate property, due to the labor, monetary, or in-kind contribution of either or both of the spouses that occurred during the marriage." R.C. 3105.171(A)(3)(a)(i) and (iii).

{¶ 12} R.C. 3105.171(A)(6)(a) defines "separate property" as including in part:

(i) An inheritance by one spouse by bequest, devise, or descent during the course of the marriage;

(ii) Any real or personal property or interest in real or personal property that was acquired by one spouse prior to the date of the marriage;

(iii) Passive income and appreciation acquired from separate property by one spouse during the marriage;

...

(vii) Any gift of any real or personal property or of an interest in real or personal property that is made after the date of the marriage and that is proven by clear and convincing evidence to have been given to only one spouse.

{¶ 13} "Passive income" is defined as: "income acquired other than as a result of the labor, monetary, or in-kind contribution of either spouse." R.C. 3105.171(A)(4). "Appreciation of separate property 'due solely to market forces, such as location and inflation' is passive appreciation and remains separate property." Gregory v. Falcon, 2023-Ohio-1741, ¶ 35 (5th Dist.), quoting Sterbenz v. Sterbenz, 2004-Ohio-4577, ¶ 5 (9th Dist.). The party arguing passive appreciation and therefore separate property bears the burden of proof. Tochtenhagen v. Tochtenhagen, 2010-Ohio-4557, ¶ 45 (11th Dist.).

{¶ 14} "There is a presumption in Ohio that an asset acquired during the course of the marriage is marital property, unless proved otherwise." Salameh v. Salameh, 2019-Ohio-5390,

¶ 28 (5th Dist.), citing Haven v. Haven, 2012-Ohio-5347, ¶ 23 (5th Dist.). "The characterization of property as separate or marital is a mixed question of law and fact, and the trial court's ruling must be supported by sufficient credible evidence." Altier v. Altier, 2015-Ohio-1526, ¶ 21 (5th Dist.). "The party seeking to establish an asset as separate property has the burden of proof, by a preponderance of the evidence, to trace the asset to separate property." Id. This court will not disturb the trial court's ruling as being against the manifest weight of the evidence if some competent, credible evidence supports the trial court's judgment. Howcroft v. Howcroft, 2010-Ohio-6410, ¶ 57 (5th Dist.), citing C.E. Morris Co. v. Foley Constr. Co., 54 Ohio St.2d 279 (1978). In State v. Thompkins, 78 Ohio St.3d 380, 387 (1997), quoting Black's Law Dictionary (6th Ed. 1990), the Supreme Court of Ohio explained the following:

Weight of the evidence concerns "the inclination of the greater amount of credible evidence, offered in a trial, to support one side of the issue rather than the other. It indicates clearly to the jury that the party having the burden of proof will be entitled to their verdict, if, on weighing the evidence in their minds, they shall find the greater amount of credible evidence sustains the issue which is to be established before them. Weight is not a question of mathematics, but depends on its effect in inducing belief." (Emphasis in original.)

{¶ 15} In weighing the evidence, however, we are always mindful of the presumption in favor of the trial court's factual findings. Eastley v. Volkman, 2012-Ohio-2179. "The underlying rationale of giving deference to the findings of the trial court rests with the knowledge that the trial judge is best able to view the witnesses and observe their demeanor, gestures and voice inflections, and use these observations in weighing the credibility of the proffered testimony." Seasons Coal Co. v. Cleveland, 10 Ohio St. 3d 77, 80 (1984); accord Eberly v. Eberly, 2026-Ohio-2262, ¶ 31.

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Related

Eastley v. Volkman
2012 Ohio 2179 (Ohio Supreme Court, 2012)
Haven v. Haven
2012 Ohio 5347 (Ohio Court of Appeals, 2012)
Sterbenz v. Sterbenz, Unpublished Decision (9-1-2004)
2004 Ohio 4577 (Ohio Court of Appeals, 2004)
Salameh v. Salameh
2019 Ohio 5390 (Ohio Court of Appeals, 2019)
C. E. Morris Co. v. Foley Construction Co.
376 N.E.2d 578 (Ohio Supreme Court, 1978)
Cherry v. Cherry
421 N.E.2d 1293 (Ohio Supreme Court, 1981)
Seasons Coal Co. v. City of Cleveland
461 N.E.2d 1273 (Ohio Supreme Court, 1984)
Martin v. Martin
480 N.E.2d 1112 (Ohio Supreme Court, 1985)
Huffman v. Hair Surgeon, Inc.
482 N.E.2d 1248 (Ohio Supreme Court, 1985)
Gregory v. Falcon
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Eberly v. Eberly
2026 Ohio 2262 (Ohio Court of Appeals, 2026)