Parsai v. Parsai

Citations

• 2025 Ohio 829

Syllabus

Divorce; division of marital property; equitable division of property; spousal support; temporary support; abuse of discretion; Civ.R. 75(N); R.C. 3105.171; de facto marriage termination; financial entanglements; bilateral; unilateral; motion for new trial; motion for relief from judgment; invited error; failure to prosecute; modification of temporary support; credit for payments during divorce proceedings; valuation of property; valuation evidence; time limits on presentation of evidence; prejudice; mootness; marriage inception date; pension; R.C. 3105.18. On Husband's assignments of error, the trial court did not abuse its discretion or err as a matter of law in rejecting a de facto marriage termination date of May 1, 2017, in favor of the final hearing date, October 11, 2023. The record supported the trial court's determination that the separation was the result of unilateral action by Wife rather than bilateral action by both parties, that there were continuing financial entanglements, and that there was insufficient evidence of the value of marital property on May 1, 2017, hampering the trial court's ability to equitably divide marital property as of that date. The trial court did not abuse its discretion or err as a matter of law by not retroactively modifying the temporary spousal-support order premised upon Husband's retirement. Husband did not prosecute his Civ.R. 75(N)(2) motion and never filed a motion to modify temporary support. The trial court did not abuse its discretion or err as a matter of law by not granting Husband credit for direct payments made to Wife during the pendency of the divorce proceedings. Trial court took payments into account in its ultimate property division determinations, and arguments regarding marital property valuation were waived where Husband failed to submit valuation evidence. The trial court did not abuse its discretion or err as a matter of law by placing time limitations on direct examination and cross-examination. Husb