Chawla v. Chawla
2014 Ohio 1188
| Ohio Ct. App. | 2014Background
- Married April 29, 2000; three children born 2003, 2005, 2008; trial court issued temporary orders designating both as custodians with a set schedule and child/spousal support obligations.
- Trial focused on Louisiana condo, Mississippi real estate and related finances, PNC line of credit, alleged financial misconduct, child support, and attorney fees.
- Parties are physicians; plaintiff (Chawla) sought modifications; guardian ad litem appointed for children.
- Trial court valued assets/liabilities as of Sept. 30, 2012 and entered a final decree on April 16, 2013, disposing marital and separate property
- Appellant challenges several financial and property rulings; the court affirms the divorce and property division.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether child support was properly calculated given high combined income | Chawla claims imputing $550,000 income and exceeding the guideline was error | Chawla contends court properly considered case-by-case factors for high income | No abuse; support upheld. |
| Whether appellee engaged in financial misconduct regarding Mississippi property | Chawla asserts misconduct and seeks equitable relief | Chawla argues no misconduct proven | Mississippi property misconduct not established; no equitable relief awarded. |
| Whether Louisiana condo was correctly classified as appellee's separate property | Chawla contends condo was marital asset | Chawla asserts sole separate property | Condo properly found as appellee's separate property. |
| Whether $40,000 attorney-fee award was equitable | Chawla argues award was improper given asset division | Award balanced by conduct and circumstances | No abuse; fee award affirmed. |
Key Cases Cited
- Apps v. Apps, 2003-Ohio-7154 (Ohio Supreme Court/2003) (imputing income requires explicit voluntary-underemployment finding and proper factors)
- Guertin v. Guertin, 2007-Ohio-2008 (Ohio App. 10th Dist. 2007) (case-by-case approach for high-income child support under R.C. 3119.04(B))
- Wolfe v. Wolfe, 2005-Ohio-2331 (Ohio App. 10th Dist. 2005) (guideline considerations when incomes exceed $150,000; not always require express 3119.22 findings)
- Bruno v. Bruno, 2005-Ohio-3812 (Ohio App. 10th Dist. 2005) (requires explicit finding and supporting evidence for voluntary underemployment)
- Heller v. Heller, 2008-Ohio-3296 (Ohio App. 10th Dist. 2008) (financial misconduct standards and appellate review)