Polacheck v. Polacheck, 2013 Ohio 5788

Divorce action between Amy and David Polacheck; three children; Husband was high-earning breadwinner, Wife cared for home and children.
Wife incurred about $40,000 in marital student-loan debt while pursuing nursing education; she obtained degree and began earning $58,000 annually.
Parties mediated most issues; dispute remained on allocation of the student-loan debt and whether to allow contact with paternal grandfather.
Trial court reserved debt allocation, final decree allocated the entire student-loan debt to Wife without an offset in property division.
Court of Appeals remanded for reevaluation of equitable division of the student-loan debt, while affirming other portions of the judgment.
Exhibit of ex parte parenting order and temporary child-support issues were treated as moot or merged into final decree for purposes of review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the marital student-loan debt should be allocated solely to Wife	Wife contends equal or more equitable allocation is required.	Husband argues Wife should bear sole responsibility.	Remanded for reevaluation of equitable debt allocation.
Whether the ex parte parenting order is reviewable on appeal	Ex parte order merits review for errors in procedure.	Issues are moot; order already executed.	Moot; merits not reached.
Whether temporary child support order merits review since merged into final decree	Temporary award should be reviewed for accuracy under guidelines.	Temporary order merged; no independent review available.	Review not addressed on merits due to merger.

Blakemore v. Blakemore, 5 Ohio St.3d 217 (Ohio 1983) (abuse of discretion standard in domestic relations)
Wolfe v. Wolfe, 46 Ohio St.2d 399 (Ohio 1976) (statutory framework for equitable division of property)
Cherry v. Cherry, 66 Ohio St.2d 348 (Ohio 1981) (property and support division viewed together)
Hoyt v. Hoyt, 53 Ohio St.3d 177 (Ohio 1990) (retirement benefits and property division considerations)