Hahn v. Hahn, 2012 Ohio 2001

Husband and Wife married in 1994 and had two children; they formed Olympic Construction and later dissolved it in 2001.
A separation agreement was signed on October 19, 2007, with Wife asserting it would be adopted by the court in divorce; Husband contends it was executed under duress and for asset protection.
Husband’s DUI, criminal convictions, and subsequent unemployment led to a protracted domestic relations proceeding; Husband attacked Wife in 2008, resulting in burglary and domestic violence convictions.
The trial court found the separation agreement valid and enforceable but conducted an evidentiary process to resolve remaining issues; it later issued a final divorce judgment with post-judgment corrections to child support and cash medical support.
The court reclassified certain equipment (Ford F350, Chevy dump truck, trailer, ATV, backhoe) as marital property and later remanded for recalculation of the asset division; it also determined Husband was voluntarily unemployed and imputed income for child support purposes.
The judgment included calculations for child support, relying on an income worksheet and allowing cash medical support contingent on health insurance adequacy.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Validity and enforcement of the separation agreement	Husband argues no meeting of the minds and duress.	Wife asserts the agreement was voluntarily entered and enforceable.	The court properly enforced the separation agreement; no abuse of discretion.
Classification of third-party equipment as marital property	Equipment remained in Husband’s possession, with titles in his father’s name.	Equipment belonged to Husband’s parents and was not owned by Husband.	Trial court erred in classifying the equipment as marital property; remand for asset reallocation.
Treatment of parental gift as income for child support	Gifts from parents should not be treated as income.	Money from parents constitutes income.	Money received from parents was income for child support purposes.
Imputation of income and voluntary unemployment	No credible evidence of ability to earn by Husband.	Husband is voluntarily unemployed; imputed income appropriate.	Court did not abuse its discretion in imputing income and determining voluntary unemployment.
Use of income figures and worksheets for child support and cash medical support	Guideline computations were not properly incorporated.	Worksheet was attached and referenced; deviations explained.	Court correctly used guideline worksheet; cash medical support upheld with conditions.

In re Adams, 45 Ohio St.3d 219 (Ohio Supreme Court 1989) (separation agreements and court’s authority to enforce)
In re Whitman, 81 Ohio St.3d 239 (Ohio Supreme Court 1998) (separation agreements and division of property on divorce)
Blakemore v. Blakemore, 5 Ohio St.3d 217 (Ohio Supreme Court 1983) (abuse of discretion standard in domestic relations)