C.S. v. M.S., 2019 Ohio 1876

Husband and Wife were married over 25 years and have two adult children; Wife primarily cared for the children and later worked as a school aide with a three‑year average income of $16,424 and monthly expenses ~ $3,000.
Husband worked long hours as a sales manager with a three‑year average income of $146,855 (this figure included bonuses).
At trial the court imputed Husband’s income at $102,003.20 (excluding bonuses), imputed Wife’s income at $20,000, and awarded Wife spousal support of $2,916.67 per month.
The parties also owned two restored Ford Mustangs purchased with marital funds; Husband performed restorations. The trial court awarded Wife $14,000 (half of the vehicles’ purchase cost) and declined to award her any share of value increase allegedly due to Husband’s efforts.
Wife appealed, arguing the trial court erred by excluding Husband’s bonus income in the spousal‑support calculation and by valuing/dividing the Mustangs based on cost rather than appreciating marital value.
The Ninth District Court of Appeals reversed and remanded, finding legal error in both the spousal‑support and property‑division analyses.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial court properly excluded Husband’s bonus income in spousal‑support calculation	Wife: trial court must consider income from all sources and treat parties as equally contributing to marital income under R.C. 3105.18(C)	Husband: bonuses are employer rewards for extra effort and should not be apportioned to Wife; excluding them avoids inequitable results	Court held exclusion misapplied the law; treating Husband’s bonuses as excluded conflicted with R.C. 3105.18(C)(2) and was an abuse of discretion, so spousal‑support determination reversed and remanded
Whether trial court correctly based Wife’s Mustang award on purchase cost and refused to compensate her for value appreciation	Wife: vehicles and their appreciation are marital property; presumption favors marital characterization and Husband bore burden to prove separate funds for restorations	Husband: he did the restoration work and the increase in value resulted from his sole efforts, so Wife should not receive appreciation absent proof of marital funds used to enhance value	Court held trial court erred by requiring Wife to prove marital funds for appreciation; presumption is that assets and appreciation are marital unless proven otherwise; property‑division decision reversed and remanded

Blakemore v. Blakemore, 5 Ohio St.3d 217 (Ohio 1983) (abuse of discretion standard defined)
Middendorf v. Middendorf, 82 Ohio St.3d 397 (Ohio 1998) (efforts by one spouse that contribute to appreciation create a marital interest)