Hunt v. Hunt

2022 Ohio 412
CourtOhio Court of Appeals
DecidedFebruary 14, 2022
Docket21CA011720
StatusPublished
Cited by5 cases

This text of 2022 Ohio 412 (Hunt v. Hunt) 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
Hunt v. Hunt, 2022 Ohio 412 (Ohio Ct. App. 2022).

Opinion

[Cite as Hunt v. Hunt, 2022-Ohio-412.]

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

WILLIAM C. HUNT C.A. No. 21CA011720

Appellant/Cross-Appellee

v. APPEAL FROM JUDGMENT ENTERED IN THE MICHELLE L. HUNT COURT OF COMMON PLEAS COUNTY OF LORAIN, OHIO Appellee/Cross-Appellant CASE No. 17DU083698

DECISION AND JOURNAL ENTRY

Dated: February 14, 2022

CALLAHAN, Judge.

{¶1} Appellant/Cross-Appellee, William Hunt (“Husband”), and Appellee/Cross-

Appellant, Michelle Hunt (“Wife”), appeal from the judgment of the Lorain County Court of

Common Pleas, Domestic Relations Division. This Court reverses and remands for further

proceedings.

I.

{¶2} Husband and Wife married in 2003 and had two children together: L.H., born in

April 2003, and W.H., born in December 2005. Husband vacated the marital home in July 2017

and filed a complaint for divorce in November 2017. Wife and the children remained in the

marital home during the proceedings, and, pursuant to temporary orders, Husband paid the

mortgage and utilities in addition to temporary support.

{¶3} A trial was held on five separate days in 2019, but the trial court’s judgment was

delayed due to the onset of the global pandemic and the court’s inability to hold an interview 2

with the children until a later date. The trial court ultimately issued its judgment in December

2020. That judgment granted the parties a divorce, named Wife the residential parent and legal

custodian of the children, awarded her spousal support, and divided the assets and liabilities of

the parties.

{¶4} Husband and Wife now appeal from various aspects of the trial court’s judgment

and raise a combined seven assignments of error for this Court’s review. To facilitate that

review, this Court reorders and combines several of the assignments of error.

II.

HUSBAND’S ASSIGNMENT OF ERROR NO. 3

THE TRIAL COURT COMMITTED REVERSIBLE ERROR WHEN IT DETERMINED THAT [HUSBAND’S] INTEREST IN THE MARITAL REAL ESTATE WAS LIMITED TO $29,410.50.

WIFE’S ASSIGNMENT OF ERROR NO. 1

THE FINDING BY THE TRIAL COURT THAT THE GIFT OF $10000 BY GRANDMOTHER WAS A JOINT GIFT TO [WIFE] AND TO [HUSBAND] AND EACH PARTY WAS EQUALLY ENTITLED TO $5000 OF THE GIFT WAS CONTRARY TO THE EVIDENCE AND TRIAL COURT ABUSED ITS DISCRETION TO THE PREJUDICE OF [WIFE].

WIFE’S ASSIGNMENT OF ERROR NO. 2

THE TRAIL (SIC) COURT ERRED TO THE PREJUDICE OF [WIFE] AND ITS DECISION WAS CONTRARY TO THE EVIDENCE WHEN IT SET OFF $5000 [WIFE] RECEIVED AS ADDITIONAL MONIES FROM [HUSBAND’S] 401(K), WITH THE $10,000 THAT WAS GIFTED TO [WIFE], BY GRANDMOTHER, PRIOR TO MARRIAGE AND WAS SEPARATE PROPERTY.

{¶5} In his third assignment of error, Husband argues that the trial court erred when it

determined that his share of the marital home was only $29,410.50. He argues that the court did

not properly credit the down payment on the home, did not credit him for mortgage and escrow

payments he made after the de facto termination date of the marriage, and did not rely on current 3

valuation figures in calculating the balance owed on the home. In her first assignment of error,

Wife argues that the trial court erred when it found that a portion of the down payment on the

marital home was a gift from her mother to Husband. Relatedly, in her second assignment of

error, Wife argues that the court erred when it relied on that same finding to award Husband an

offset elsewhere in its judgment. Because all three assignments of error are linked to the trial

court’s determination of the parties’ respective interests in the marital home, this Court will

address them together.

{¶6} During divorce proceedings, a trial court must determine what property

constitutes marital property and what constitutes separate property. R.C. 3105.171(B). See also

R.C. 3105.171(A)(3)(a) (defining “marital property”) and 3105.171(A)(6)(a) (defining “separate

property”). To do so, the court must consider the duration of the marriage. Tustin v. Tustin, 9th

Dist. Summit No. 27164, 2015-Ohio-3454, ¶ 17. It is presumed that the duration of a marriage

will be “the period of time from the date of the marriage through the date of the final hearing * *

*[,]” R.C. 3105.171(A)(2)(a), but a trial court has “the authority to use a de facto termination

date in certain cases, where principles of equity dictate that use of the final hearing date is

inappropriate.” Budd v. Budd, 9th Dist. No. 25469, 2011-Ohio-565, ¶ 14. See also R.C.

3105.171(A)(2)(b). A determination of the duration of the marriage is critical because the

duration of the marriage will determine the valuation of the marital assets. Tustin at ¶ 17. See

also Budd at ¶ 14; Schwieterman v. Schwieterman, 3d Dist. Logan No. 8-19-49, 2020-Ohio-

4881, ¶ 43 (“The duration of a marriage provides a trial court with a timeframe for determining

the value of marital assets that fluctuate in value.”). “[T]he court must choose a specific date for

purposes of valuation and use it consistently * * *.” Elliot-Thomas v. Lewis, 9th Dist. Summit

No. 29164, 2019-Ohio-3870, ¶ 7. 4

{¶7} While a trial court’s decision to use the final hearing date or a de facto date to

define the duration of a marriage is a discretionary one, Budd at ¶ 8, the classification of property

as marital or separate is a fact-based determination that this Court reviews under the manifest

weight of the evidence standard. Kolar v. Kolar, 9th Dist. Summit No. 28510, 2018-Ohio-2559,

¶ 30. When applying that standard, this Court “‘“weighs the evidence and all reasonable

inferences, considers the credibility of witnesses and determines whether in resolving conflicts in

the evidence, the [finder of fact] clearly lost its way and created such a manifest miscarriage of

justice that the [judgment] must be reversed and a new [hearing] ordered.”’” (Alternations made

in Tewarson.) Eastley v. Volkman, 132 Ohio St.3d 328, 2012-Ohio-2179, ¶ 20, quoting

Tewarson v. Simon, 141 Ohio App.3d 103, 115 (9th Dist.2001), quoting State v. Thompkins, 78

Ohio St.3d 380, 387 (1997), quoting State v. Martin, 20 Ohio App.3d 172, 174 (1st Dis.1983).

In weighing the evidence, this Court “must always be mindful of the presumption in favor of the

finder of fact.” Eastley at ¶ 21.

{¶8} Once the duration of a marriage has been established and property has been

designated marital or separate property, a trial court must divide the property equitably between

spouses. R.C. 3105.171(B). “R.C. 3105.171(C)(1) requires trial courts to divide marital

property equally, except to the extent that an equal division would be inequitable.” Schoch v.

Schoch, 9th Dist. Lorain No. 18CA011382, 2019-Ohio-1394, ¶ 24. If an equal division would be

inequitable, the court must divide the marital property in a manner it deems equitable after

considering the factors set forth in R.C. 3105.171(F). Neville v. Neville, 99 Ohio St.3d 275,

2003-Ohio-3624, ¶ 5. “A trial court enjoys broad discretion in fashioning an equitable division

of marital property.” Stepp v. Stepp, 9th Dist. Medina No. 03CA0052-M, 2004-Ohio-1617, ¶ 10.

Consequently, “its judgment will not be disturbed absent an abuse of discretion.” Neville at ¶ 5. 5

{¶9} The trial court determined that the parties were married on August 23, 2003.

Although the final hearing date occurred on October 24, 2019, the court found that it would be

inequitable to use that date as the date of the termination of the marriage.

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2022 Ohio 412, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hunt-v-hunt-ohioctapp-2022.