Dickinson v. Dickinson, 2012 Ohio 4856

Dickinsons married in 1998; Jeanne filed for divorce in 2011; court heard spousal support, debt, and retirement matters after agreed entries subdividing assets.
Wife is disabled with COPD, receives $903 monthly Social Security Disability; husband earns about $49,000 annually (net ~ $1,040 every two weeks).
Equitable real estate settlement gave wife $20,668.50 equity; she received $5,542.82 from husband’s deferred compensation and Honeywell stock valued at $1,735.80.
Marital debts identified in agreed entries: Bank of America $11,161.69; Department of Transportation Credit Union $5,028; wife also to pay about $913.12 arising in her name.
Trial court declined spousal support, ordered wife to pay $11,161 debt to Bank of America, and awarded wife half of husband’s retirement benefits; no spousal-support jurisdiction retained.
Court of Appeals reversed on spousal support and debt allocation, affirming other aspects, and remanded for further proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did trial court abuse discretion by denying spousal support?	Dickinson contends denial was error given income disparity and needs.	Dickinson asserts court acted within discretion based on factors.	Yes; spousal support awarded (remand for amount/time).
Did trial court err by treating marital debts as non-marital and allocating them to Dickinson?	Dickinson argues debts were stipulated marital debts and should be equitably divided.	Dickinson contends division was appropriate under discretion and record.	Yes; improper characterization/allocation; remanded.

Smith v. Smith, 182 Ohio App.3d 375 (2009-Ohio-2326) (abuse of discretion standard in domestic relations)
Blakemore v. Blakemore, 5 Ohio St.3d 217 (1983) (abuse of discretion defined)
Buzard v. Buzard, 2d Dist. Clark No. 2011 CA 18, 2012-Ohio-2658 (2012) (Broad discretion in equitable division of property)
Ulliman v. Ulliman, 2008-Ohio-3876 (2d Dist. Montgomery) (debt treated as part of marital property for division)