Leithauser v. Leithauser

2024 Ohio 1497, 242 N.E.3d 831
CourtOhio Court of Appeals
DecidedApril 19, 2024
Docket2023-CA-43
StatusPublished

This text of 2024 Ohio 1497 (Leithauser v. Leithauser) 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
Leithauser v. Leithauser, 2024 Ohio 1497, 242 N.E.3d 831 (Ohio Ct. App. 2024).

Opinion

[Cite as Leithauser v. Leithauser, 2024-Ohio-1497.]

IN THE COURT OF APPEALS OF OHIO SECOND APPELLATE DISTRICT CLARK COUNTY

SHARON A. LEITHAUSER : : Appellee : C.A. No. 2023-CA-43 : v. : Trial Court Case No. 21-DR-0015 : DANIEL E. LEITHAUSER : (Appeal from Common Pleas Court- : Domestic Relations) Appellant : :

...........

OPINION

Rendered on April 19, 2024

STACEY ROBERT PAVLATOS, Attorney for Appellant

SHARON A. LEITHAUSER, Pro Se Appellee

.............

HUFFMAN, J.

{¶ 1} Daniel E. Leithauser appeals from a judgment entry and decree of divorce

from Sharon A. Leithauser. Specifically, Daniel challenges the trial court classification

of a mortgage on the former marital residence on Tudor Circle in Springfield as a non-

marital debt. For the reasons that follow, we conclude that the debt in question was a

marital debt and the trial court erred in failing to treat it as such in the division of property. -2-

Accordingly, the judgment of the trial court is reversed as to the property division only and

remanded for further proceedings on that issue consistent with this opinion. In all other

respects, the judgment of the trial court is affirmed.

Facts and Procedural History

{¶ 2} The parties were married in 1988. During the parties’ marriage, they had

exchanged their family residence on Tudor Circle, which was encumbered by a mortgage,

with that of Daniel’s parents on Kramer Road, which was mortgage-free. Pursuant to an

oral agreement with Daniel’s parents, Daniel and Sharon continued to pay the Tudor

Circle mortgage. The Tudor Circle property was refinanced twice by Daniel and Sharon,

and Daniel’s parents ultimately purchased the property after a foreclosure action, leaving

Daniel and Sharon mortgage-free, although they continued to service the Tudor Circle

mortgage taken out by Daniel’s parents.

{¶ 3} Sharon filed a complaint for divorce on January 2021. Daniel filed an

answer and counterclaim, and Sharon answered the counterclaim in February 2021.

{¶ 4} A hearing occurred over six days, after which the court asked the parties to

brief the issues. On July 17, 2023, Daniel filed a memorandum asserting, in relevant

part, that he wished to retain the Kramer Road property, and that the outstanding

mortgage indebtedness on the Tudor Circle property, which the parties had swapped with

his parents, had a balance of $81,793 as of November 24, 2022. Daniel also asserted

that, considering tax liens totaling $9,710, the equity in the Kramer Road property was

$69,365.

{¶ 5} On July 28, 2023, Sharon filed a memorandum requesting that the Kramer -3-

Road property be sold, with the net proceeds to be divided between the parties, or that

she be paid half of the appraised value. She noted that her appraiser had valued the

property at $215,000, and Daniel had not offered an alternative appraisal. Sharon

asserted that the debt on the Tudor Circle property was not a marital debt, because the

mortgage was in Daniel’s mother’s name and there was no written agreement signed by

the parties under which they could be held liable for the debt. Sharon noted that Daniel’s

mother had been paying the mortgage since September 2021, and she asserted that any

payments by the parties toward the Tudor Circle mortgage had been gifts between family

members.

{¶ 6} On August 10, 2023, the trial court issued a Judgment Entry and Decree of

Divorce; in the decree, the debt due to Daniel’s parents associated with the Tudor Circle

mortgage was treated as a non-marital debt. Daniel appeals.

Assignment of Error and Analysis

{¶ 7} Daniel asserts the following sole assignment of error:

THE TRIAL COURT IMPROPERLY APPLIED THE PAROL

EVIDENCE RULE TO PRECLUDE CONSIDERATION OF UNDISPUTED

EVIDENCE OF THE AGREEMENT BETWEEN THE APPELLANT AND

APPELLEE WITH THE APPELLANT’S PARENTS WHEREIN THE

PARTIES AND THE PARENTS EXCHANGED THEIR RESIDENCES

SUBJECT TO THE PROMISE BY THE APPELLANT AND APPELLEE TO

CONTINUE TO PAY AND ULTIMATELY SATISFY THE MORTGAGE

OBLIGATION ENCUMBERING THE RESIDENCE THEY TRANSFERRED -4-

TO THE PARENTS IN EXCHANGE FOR A MORTGAGE-FREE

RESIDENCE.

{¶ 8} Daniel argues that the trial court erred treating the debt on the Tudor Circle

property as a non-marital debt.

{¶ 9} In issuing the final decree of divorce, the trial court made the following

findings: The de facto termination date of the parties’ marriage was June 30, 2023. The

parties were joint owners of the marital residence at 615 Kramer Road in Springfield.

Regarding the Tudor Circle property, the court found that the outstanding debt was

$81,793 as of November 24, 2022, that “that there were no promissory notes or other

legal contracts in writing” obligating either of the parties to make mortgage payments for

Daniel’s parents, and that any such obligation was not legally enforceable without a

written agreement due to the parol evidence rule. As such, the court found that the

mortgage on the Tudor Circle property was the legal obligation of Daniel’s mother1 and

that the parties had no legal obligation to pay the mortgage. The court found that Daniel

had not met his burden of proof to establish that the mortgage on the Tudor Circle property

was “a valid marital debt” to be offset against the other marital assets, including the fair

market value of the Kramer Road property.

{¶ 10} The court found that the fair market value of the Kramer Road marital

residence was $215,000, that the parties needed to make $28,766.11 in repairs in order

to sell the house, and that there were tax liens of $9,710 on the property. Accounting for

1 Both of Daniel’s parents had been named on the Tudor Circle mortgage, but his father died while the parties’ divorce was pending, so the trial court discussed the mortgage as the responsibility of Daniel’s mother in the divorce decree. -5-

these factors, the court found the net equity in Kramer Road property to be $176,523.89

and that half of that number – or $88,261.95 -- was Sharon’s share of the marital property.

The court also found that Sharon owed Daniel $4,729.50 for his equitable interest in her

vehicle, $2,841.39 for his equitable interest in her life insurance policy, and $3,605.34 for

his equitable interest in her retirement account. Offsetting these numbers, the court

found that Daniel owed Sharon $77,085.72 in order to achieve an equitable division of

the parties’ marital property. The court gave Daniel the option to purchase the Kramer

Road residence by paying Sharon $77,085.72 within 90 days of the order; otherwise, the

court ordered that the property be listed for sale by a mutually agreeable realtor at a

mutually agreed upon a price. The court granted exclusive occupancy of the Kramer

Road property to Daniel and ordered that he be responsible for all utilities and insurance,

but that the parties be equally responsible for all real estate taxes.

{¶ 11} Daniel argues on appeal that the parol evidence rule did not apply and that

the debt owed on the Tudor Circle property was a marital debt. He acknowledges that

there was no written agreement memorializing the agreement between Daniel and

Sharon with Daniel’s parents that, as part of the consideration for their exchange of

residences, Daniel and Sharon would ensure that Daniel’s parents “would ultimately have

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Cite This Page — Counsel Stack

Bluebook (online)
2024 Ohio 1497, 242 N.E.3d 831, Counsel Stack Legal Research, https://law.counselstack.com/opinion/leithauser-v-leithauser-ohioctapp-2024.