Brodbeck v. Brodbeck
2025 Ohio 980
Ohio Ct. App.2025Background
- Leah Brodbeck (Appellant) and Brett Brodbeck (Appellee) were married for about 3.5 years (August 12, 2018–November 21, 2022) and had no children.
- Leah Brodbeck, a teacher, had an STRS pension that increased by $57,240.13 during the marriage; Brett Brodbeck is a chiropractor with interests in several small businesses, which the court ultimately valued at $0.
- Both parties filed for divorce; after a Magistrate’s Decision, both filed objections.
- The trial court reviewed and adopted the Magistrate’s decision in part, made modifications, and issued the Divorce Decree, leading Leah to appeal.
- Six assignments of error were raised by Leah Brodbeck on appeal, focusing largely on property division, business valuation, and counsel’s effectiveness.
- The Appellate Court applied the abuse of discretion standard and affirmed the trial court’s judgment in all respects.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Valuation & division of STRS pension | Pension not valued correctly; inequitable division | Applied coverture formula; entitled | Division was reasonable and supported by evidence |
| Offset of STRS by Social Security benefits | Trial court failed to offset pension by SS benefits | No Social Security benefit earned | Waived on appeal, no error found |
| Failure to find financial misconduct | Defendant concealed/dissipated assets (B Group LLC) | All finances disclosed; no misconduct | No evidence of misconduct; decision reasonable |
| Failure to consider 2020 tax refund | Court did not consider refund | -- | Waived/not raised below; overruled |
| Valuation of defendant's businesses | Court failed to include valuable assets | Business interests worth $0 | Valuation supported by credible evidence |
| Ineffective assistance of counsel | Received ineffective legal assistance | -- | Not grounds for reversal in this context |
Key Cases Cited
- Blakemore v. Blakemore, 5 Ohio St.3d 217 (Ohio 1983) (defined abuse of discretion standard)
- Lotz v. Lotz, 2014-Ohio-5625 (business valuation under manifest weight standard)
