Naiman v. Naiman

Citations

• 2025 Ohio 1589

Syllabus

Trial court did not err in finding parent voluntarily unemployed and imputing income for purposes of child-support calculation despite the parent's 100% VA disability status where medical documentation of inability to work was lacking and evidence contradicted claimed inability to work. Trial court erred in failing to award attorney fees specifically related to motion to compel discovery where the motion to compel is granted under Civ.R. 37, mandating attorney fees unless specific exceptions apply, and the trial court had affirmed the magistrate's discovery sanctions order but later denied all attorney fees without addressing the prior ruling or explaining why the mandate of Civ.R. 37 should not apply. Trial court did not err in characterizing cash as marital property rather than separate property where the party claiming separate property failed to meet that party's burden of proving separate property. Trial court did not err in accepting one party's expert valuation of a business rather than the other party's expert valuation where competent evidence supported the accepted valuation. Trial court erred in failing to address disputed property in the property division where the property was explicitly listed as a disputed issue in joint trial stipulations, and both parties testified to its existence, but the divorce decree made no mention of it.