Shoenfelt v. Shoenfelt, 2015 Ohio 225

Robert and Jennifer Shoenfelt married on May 2, 1987 and have two children; one child remained a minor when divorce filed in 2010.
The final hearing in March 2010 addressed $70,000 in loans to Robert, Robert’s deferred compensation, Robert’s reimbursement claim for marital debts, and Jennifer’s student loans.
The magistrate initially set the de facto termination date as November 2006, and proposed that Robert’s $70,000 loans be treated as a marital debt and Jennifer receive half of Robert’s deferred compensation upon vesting.
Robert paid approximately $222,135 in marital debt from November 2006 to the final hearing; Jennifer deposited money post-2006 to cover some expenses, including childcare.
Jennifer’s student loans totaling over $250,000 were argued by Robert to have benefited the marriage; the court eventually treated them as marital debt, with other related living expenses considered.
The trial court ultimately adopted November 2006 as the termination date and allocated assets and debts accordingly, denying Robert’s reimbursement claim and ordering division of unvested deferred compensation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Reimbursement for post-termination marital debts	Robert argues he paid debts after de facto termination and seeks reimbursement.	Jennifer contends the court properly denied reimbursement based on marital funds and use of the home.	No reversible error in denying reimbursement for post-termination debts.
Classification of Jennifer's medical school loans as marital debt	Robert contends the loans were not the couple’s debt and should belong to Jennifer alone.	Jennifer contends the loans were marital debt benefiting both and should be shared.	Student loans were properly classified as marital debt and allocated between the parties.
Treatment of unvested deferred compensation	Robert argues unvested assets should not be marital property and should not be divided.	Jennifer contends unvested compensation can be a marital asset subject to division when vesting occurs.	Unvested deferred compensation was properly considered marital and equitably divided.

Neville v. Neville, 99 Ohio St.3d 275 (2003-Ohio-3624) (broad discretion in asset allocation; abuse of discretion standard)
Schwarck v. Schwarck, 2012-Ohio-3902 (3d Dist. Auglaize No. 2-11-24, 2012) (abuse of discretion in asset division; Dill factors applicability)
Stump v. Stump, 2007-Ohio-6553 (3d Dist. Logan No. 8-07-11, 2007) (abuse of discretion standard; consideration of equities in division)
Holcomb v. Holcomb, 44 Ohio St.3d 128 (1989) (pension plans as marital assets; vesting considerations)
Daniel v. Daniel, 139 Ohio St.3d 275 (2014-Ohio-1161) (future benefits may have value; weighing factors in division)