Hoskins v. Hoskins, 2013 Ohio 1126

Robert Hoskins filed for divorce from Kristen Hoskins in 2003; they had two children and shared custody.
Trial court valued marital home for equity at $370,000, but evidence showed only $275,000 for the property as a whole; subdivision/exact sale viability was not proven.
The court awarded Kristen $43,391.50 in marital equity based on the improper valuation.
Mr. Hoskins argued this improper valuation affected spousal and child support calculations, as well as overall finances.
Mr. Hoskins contended he was voluntarily underemployed, impacting child-support determinations.
The court adopted a standard visitation schedule over a proposed parenting plan from a parenting investigator, and ordered Mr. Hoskins to pay half of Kristen's attorney fees.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the marital property valuation was improper	Hoskins contends valuation was unsupported	Hoskins argues trial court correctly valued property	Valuation improper; must be reversed
Impact of valuation on spousal/child support	Equity amount affected support calculations	Support should reflect corrected valuation	Remand to adjust spousal support per corrected valuation
Whether Mr. Hoskins was properly characterized as voluntarily underemployed for child support	Underemployment determination supported	Court acted within discretion	Court did not abuse discretion; underemployment supported
Whether the trial court abused discretion in parenting schedule	Investigator-proposed schedule should have been adopted	Trial court acted within discretion to deviate from plan	No reversible error; discretion exercised appropriately
Whether the attorney-fee award was proper	Award inappropriate due to collateral matters	Award justified by litigation conduct	No error; award upheld

Rock v. Cabral, 67 Ohio St.3d 108 (Ohio 1993) (abuse of discretion standard for imputing income in child support)
Metz v. Metz, 2007-Ohio-549 (1st Dist. 2007) (courts may award attorney fees for protracted litigation)