Mullet v. Mullet, 2017 Ohio 7152

Gerald and Catherine Mullet married in 1990; Gerald owned and operated Satellite Vision, the couple’s sole source of income during the marriage.
The parties owned a marital residence and jointly held real property on Wooster Road that housed Satellite Vision and a rental unit; the Wooster Road building construction began before marriage and finished after.
After Catherine filed for divorce in November 2013, a magistrate’s temporary order required Gerald to vacate the marital home and ordered Catherine to pay mortgage/taxes/insurance unless the business met a sales threshold, and gave Gerald possession and profits from Satellite Vision.
Catherine paid nearly all mortgage payments after the temporary order (initially using an inheritance and later by selling marital gold coins); the magistrate and trial court refused to grant her any credit for the payments and ordered an equal split of home sale proceeds.
The magistrate found Gerald had an 85% separate interest in the Wooster Road property based on pre-marriage expenditures; the trial court adopted that finding.
The Ninth District Court of Appeals reversed and remanded: it held the trial court abused its discretion by denying Catherine an equity credit for mortgage payments and erred in awarding Gerald an 85% separate interest in the Wooster Road property.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Wife is entitled to credit for mortgage payments made pursuant to temporary orders	Mullet: She paid mortgage payments (using separate inheritance and by liquidating marital gold) after being cut off from business income and is entitled to an equity credit for principal reduction.	Husband: Wife benefited from living in the home; no credit warranted.	Court: Reversed — trial court abused discretion in denying any equity credit; remanded to quantify credit.
Whether the court lawfully divided marital residence equity without detailed written findings under R.C. 3105.171(G)	Mullet: Trial court failed to explain denial of equity credit—needs written findings.	Husband: (implicit) Equal division appropriate.	Court: Moot given resolution of mortgage-credit issue; not addressed further.
Whether Husband proved an 85% separate-property interest in Wooster Road property	Mullet: Husband failed to trace separate interest beyond pre-marriage expenditures; the 85% figure lacks evidentiary support.	Husband: Building was ~80–85% complete pre-marriage and offered receipts totaling $43,990.61 to support separate interest.	Court: Reversed — Husband only traced $43,990.61 of separate investment; record does not support an 85% separate interest; remanded.

Blakemore v. Blakemore, 5 Ohio St.3d 217 (Ohio 1983) (definition of abuse of discretion standard)
Eastley v. Volkman, 132 Ohio St.3d 328 (Ohio 2012) (standard for civil manifest-weight review and weighing credibility)