Galinis v. Galinis, 2017 Ohio 7831

Joseph and Christine Galinis married in 1994; three children (two emancipated) live in the marital home. Divorce complaint filed by Husband on Sept. 2, 2015.
Trial court issued an Exhibit D order requiring paychecks to be deposited into a joint account; parties maintained two joint accounts (Huntington and First Merit) with equal access.
Disputed account activity: Wife’s pay was direct‑deposited to Huntington and she transferred funds to First Merit and used joint funds (including a $9,800 transfer from insurance proceeds). Husband opened a personal account and stopped depositing paychecks into the joint accounts in Feb. 2016; both used credit cards and made payments above minimums.
Assets: marital residence valued at $265,000 (mortgage + HELOC left ~$54,225 equity); Wife’s STRS retirement account had a marital portion; Husband owned half of Aspen Homes (S corp) showing recent losses but some historical dividends.
Magistrate denied Husband’s motions to show cause, awarded residence to Husband, denied spousal/child support, and awarded Husband 10% of the marital portion of Wife’s STRS. Trial court adopted the magistrate’s decision; Husband appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether magistrate’s factual findings were against the manifest weight of the evidence	Husband: magistrate ignored Wife’s willful violations of Exhibit D (unauthorized withdrawals, failure to deposit paychecks) and other critical testimony	Wife: provided detailed accounting and explanations; Husband also overdrew accounts and stopped depositing pay	Court: Findings supported by competent evidence; not against manifest weight — Overruled Husband’s challenge
Whether property division (including STRS offset) was inequitable / misapplication of law	Husband: should receive 50% of net difference between marital portions (i.e., larger share of Wife’s STRS); court failed to account for his earning capacity and business losses	Wife: overall distribution roughly equal; Aspen Homes had value and some income; 10% award from STRS reasonable given Husband received bulk of marital assets	Court: Abuse of discretion not shown; distribution equitable under R.C. framework; 10% STRS award affirmed

Fletcher v. Fletcher, 68 Ohio St.3d 464 (1994) (appellate court will not reweigh evidence if competent evidence supports trial court)
Ross v. Ross, 64 Ohio St.2d 203 (1980) (standards for appellate review of family‑court factual findings)
Cherry v. Cherry, 66 Ohio St.2d 348 (1981) (property‑division reviewed for abuse of discretion)
Blakemore v. Blakemore, 5 Ohio St.3d 217 (1983) (abuse of discretion standard defined)