Moniz v. Moniz

2026 Ohio 159
Ohio Court of Appeals·Decided January 20, 2026·No. CA2025-03-015·Published

Opinion

IN THE COURT OF APPEALS

TWELFTH APPELLATE DISTRICT OF OHIO WARREN COUNTY

SANDI MONIZ, :

CASE NO. CA2025-03-015

Appellee and Cross-Appellant, :

OPINION AND

vs. : JUDGMENT ENTRY 1/20/2026

THOMAS MONIZ, :

Appellant and Cross-Appellee. :

:

APPEAL FROM WARREN COUNTY COURT OF COMMON PLEAS DOMESTIC RELATIONS DIVISION Case No. 21 DR 42975

Mitchell W. Allen, for appellee and cross-appellant.

Smith, Meier & Webb, LPA, and Andrew P. Meier and Chase T. Kirby, for appellant and cross-appellee.

OPINION

SIEBERT, J.

{¶ 1} Sandi and Thomas Moniz ("Wife" and "Husband" respectively) appeal the decree of divorce entered by the Warren County Court of Common Pleas, Domestic

Relations Division. Each party asserts two assignments of error. In his assignments of error, Husband asserts the magistrate erred by finding one of the parties' bank accounts to be marital property and by failing to equitably divide another account between the parties. In her first assignment of error, Wife argues the court abused its discretion by giving Wife marital assets equaling the purchase price of Husband's new home versus the price of the home as stated in the parties' temporary agreed order. Next, Wife claims the trial court erred by failing to classify and divide custodial accounts held by the parents in the name of their now adult children.

{¶ 2} We overrule each assignment of error. Husband failed to provide sufficient documentary evidence and factually support his arguments regarding the at issue accounts. Wife similarly provided no reason for us to consider the parties' "temporary agreed order" to be a binding contract between the parties which required the trial court to divide the parties’ assets differently than it did. Finally, despite Wife's assertion to the contrary, this court has clearly held that domestic relations courts do not have jurisdiction over custodial accounts.

Brief Factual and Procedural Background

{¶ 3} The parties were married in 1989. Two children, now adults, were born to the marriage. Wife filed a complaint for divorce on October 20, 2021. After a brief attempt to reconcile, Husband filed a counterclaim on Feb 9, 2022. The magistrate held the parties' final divorce hearing in May and September of 2023 and issued a decision recommending divorce in October of 2023. The magistrate's decision stated that "for the purpose of making a division of marital property," the parties marriage lasted from August 12, 1989, until October 20, 2021, when Wife filed her complaint for divorce. Each party filed objections to the magistrate's decision, but the trial court overruled them all. The trial court issued a divorce decree in February of 2025.

{¶ 4} Both parties now appeal. Further facts relevant to each parties' assignments of error will be discussed below.

Husband's First Assignment of Error:

Property Classification of the Merrill Edge Account

Factual Background

{¶ 5} The parties opened, utilized, and transferred funds to various bank accounts during the marriage. One of these accounts is a Merrill Edge account (the "Merrill Edge Account"), and the parties dispute the origins of the money in this account. Husband asserts that the money in the Merrill Edge Account originates from funds he deposited into a Hamilton Standard Credit Union account (the "Hamilton Standard Account") while employed there. These deposits occurred prior to the marriage but while the parties were living together. During this time, the parties maintained separate bank accounts, but also maintained a joint account, for shared expenses. Husband testified that he funded the Hamilton Standard Account with his earnings and only he could deposit money into the account because the bank was located in a defense contractor building to which only employees had access. Husband argued that when the parties moved from Connecticut to Arizona, the Hamilton Standard Account funds were used to open a different account with both parties being named on the account. No additional deposits were made into this account, and over time, the account's banking institution eventually became Merrill Edge. Wife acknowledged only Husband could deposit into the Hamilton Standard Account due to the credit union's location, but asserted that did not mean he earned all the money deposited into it.

{¶ 6} The magistrate found the Merrill Edge Account to be marital property. It found "[t]here was no documentation provided that only Husband's pay went into the Hamilton Standard [Account] . . . [I]t is not clear that the account was funded by just one

of the parties." In adopting the magistrate's decision, the trial court also noted that Husband did not prove that only he funded the Hamilton Standard Account. The trial court further observed that both parties' names were on the Hamilton Standard Account. While recognizing Wife did not remember much about the Hamilton Standard Account, the trial court discounted this fact citing that the relevant "sequence of events [occurred] over 35 years ago."

Standard of Review and Applicable Law

{¶ 7} We review the classification of property or debt as marital or separate under the manifest weight of the evidence standard and will not reverse a trial court's classification if it is supported by competent and credible evidence. Smith v. Smith, 2023- Ohio-982, ¶ 28 (12th Dist.).1 In determining whether competent and credible evidence exists, "'[a] reviewing court should be guided by a presumption that the findings of a trial court are correct, since the trial judge is best able to view the witnesses and observe their demeanor, gestures, and voice inflections, and use those observations in weighing the credibility of the testimony.'" Grow v. Grow, 2012-Ohio-1680, ¶ 11 (12th Dist.), quoting Barkley v. Barkley, 119 Ohio App.3d 155, 159 (4th Dist. 1997).

{¶ 8} Under Ohio law, a party claiming a separate interest in property must establish that interest by a preponderance of the evidence. Todor v. Ballesteros-Cuberos, 2024-Ohio-4525, ¶ 9 (12th Dist.), citing Peck v. Peck, 96 Ohio App.3d 731, 734 (12th Dist. 1994). "This standard requires the claiming party to demonstrate that it is more likely than not that the asset in question is indeed separate property, rather than marital property subject to division in the divorce proceedings." Id. Separate interests in property "may be commingled with marital property without losing its distinct status, provided . . . it remains

1. Both parties incorrectly assert that we review the trial court's determination for an abuse of discretion.

traceable." Id. at ¶ 22, citing R.C. 3105.171(A)(6)(b).

{¶ 9} "Marital property" includes "[a]ll real and personal property that currently is owned by either or both of the spouses . . . and that was acquired by either or both of the spouses during the marriage." R.C. 3105.171(A)(3)(a)(i). "'Marital property' does not include any separate property." R.C. 3105.171(A)(3)(b). In turn, "separate property" includes, but is not limited to real or personal property—or interest in real or personal property—acquired by one spouse prior to the marriage or after the decree of legal separation. Id. at (A)(6). Importantly, "[t]he commingling of separate property with other property of any type does not destroy the identity of the separate property as separate property, except when the separate property is not traceable." R.C. 3105.171(A)(6)(b).

Analysis

{¶ 10} Husband argues the magistrate and trial court erred in finding the Merrill Edge Account to be marital property because "Ohio law does not require . . . documentary proof of all transactions in a tracing analysis" (Emphasis in original.). Despite presenting a great deal of testimony and evidence seeking to trace the Merrill Edge Account to Hamilton Standard, he asserts on appeal "the only part of the tracing analysis he did not have was the deposit of his earnings in the Hamilton Standard Credit Union savings account."

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