Crandall v. Crandall, 2021 Ohio 3276

Christopher and Elizanna Crandall married in 2004; they signed a prenuptial agreement and have no children.
Christopher filed for divorce in 2016; final hearing was set for June 2017.
Elizanna obtained new counsel two weeks before trial and moved for a continuance; the trial court denied the continuance.
The trial court’s May 2018 divorce decree awarded assets (including a UBS retirement account and a house) but contained internally inconsistent and ambiguous provisions about dividing the UBS account and allocating active vs. passive appreciation on the house.
Both parties appealed (Elizanna appealed; Christopher cross‑appealed). The Ninth District held the decree was not a final, appealable order because it was indefinite and contained conflicting directives, and dismissed both appeals.
A concurring/dissenting judge would have found the continuance denial an abuse of discretion and remanded for a new trial.

Issue	Wife's Argument	Husband's Argument	Held
Division of UBS retirement account	Trial court misidentified two accounts, issued conflicting orders, so division unclear	Account is identifiable and awarded to Husband; any marital portion should be split	Judgment ambiguous about how single UBS account is divided; court cannot determine parties’ rights; issue contributes to nonfinal decree
Allocation of appreciation on marital residence (active vs passive)	Court failed to quantify or provide method to calculate active vs passive appreciation	Court correctly allocated passive appreciation to Husband and traced $10,000 of Wife’s separate property for active appreciation	Decree failed to state how much appreciation is active vs passive or how to calculate shares; indefinite and not enforceable
Finality / subject‑matter jurisdiction	Errors in decree justify appeal; appellate review appropriate	Cross‑appeal raises plain‑error arguments but same finality problem exists	Decree is not definite/final or susceptible to enforcement; appellate court lacks jurisdiction and dismisses appeals
Denial of continuance (dissenting view)	Denial was unreasonable given new counsel’s need to prepare; merits new trial	Husband’s counsel did not object to continuance at trial and deferred to court	Majority did not reach merits; dissent would find abuse of discretion and remand for new trial

Harkai v. Scherba Industries, Inc., 136 Ohio App.3d 211 (9th Dist. 2000) (a judgment must be definite enough to permit enforcement and inform parties of their rights)
Ostmann v. Ostmann, 168 Ohio App.3d 59 (9th Dist. 2006) (distinguishing active vs. passive appreciation and tracing requirements in property division)