Carson v. Manubay

Citations

• 2023 Ohio 2015

Syllabus

Property that is acquired \during the marriage\ is classified as marital property unless a party proves that the property satisfies the statutory definition of \separate property.\ Income that a party earns during the marriage and uses to make payments on a marital loan is not separate property just because the income is earned after the date on which the parties' financial accounts are valued. Money deposited by a third party into a party's separate bank account is not that party's separate property unless the party proves that the money was intended as a gift to that party alone. A trial court may award reasonable and appropriate spousal support after considering all the applicable statutory factors. An award of a quarter of a party's income each year for three years plus a third of the party's bonus pay may be a reasonable and appropriate award.