Williams v. Williams, 2025 Ohio 1319

Husband (Lawrence E. Williams) and Wife (Theresa A. Williams) were married in 1991 and acquired several properties during their marriage.
Financial difficulties arose near the end of the marriage, leading to defaults on mortgage and tax payments.
Husband’s sister, Beth Williams, provided substantial financial advances (totaling over $200,000) to cover mortgage, taxes, repairs, and attorney fees; some properties were eventually bought by Beth’s company.
The parties agreed that the sale proceeds from the real estate were marital property but disputed the proper division of these and Beth’s advances.
The trial court assigned only $2,000 of Beth’s advances as marital debt (to Wife), treated other advances as gifts or Husband’s separate liability, and did not make detailed findings on large sums advanced by Beth.
On appeal, Husband challenged the failure to classify and allocate these advances properly under Ohio’s property division statute (R.C. 3105.171(G)).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Failure to classify Beth’s advances as marital debt	Husband: The court failed to make explicit findings or properly classify Beth’s $182,869.74 and $17,464.52 advances; these should be considered marital debts and equitably divided.	Wife: Argued lack of knowledge of most advances; claimed they were not marital debts but gifts or Husband’s separate responsibility.	Court found trial court did not make the necessary written findings of fact; reversed and remanded for explicit classification and allocation under R.C. 3105.171(G).
Sufficiency of findings under R.C. 3105.171(G)	Husband: The trial court’s decision was too vague, lacking details necessary for appellate review.	Wife: No direct response; asserted lack of knowledge re: debts.	Court held written findings were insufficient for review and required detailed findings on all advances.
Treatment of Beth’s $182,869.74 advance	Husband: Improper to assign as his separate debt; should be marital.	Wife: Maintained advance was not acknowledged by her; not her debt.	Court: Issue not reviewable until trial court makes proper findings on nature of advances.
Allocation of unidentified liabilities	Husband: Court failed to specify what liabilities, if any, were allocated to him.	Wife: No claim to specific liability; wants to be held harmless.	Court: Remanded to specify all liabilities and clarify allocation.

Roetting v. Roetting, 2015-Ohio-2461 (Ohio Ct. App. 2015) (describes two-step process and written findings requirement for marital property division)
Smith v. Smith, 2017-Ohio-7463 (Ohio Ct. App. 2017) (rules for classifying and allocating marital/separate debts)
Kaechele v. Kaechele, 35 Ohio St.3d 93 (Ohio 1988) (findings of fact requirement for property division)
Ornelas v. Ornelas, 2012-Ohio-4106 (Ohio Ct. App. 2012) (starting point for asset/debt division is equal distribution unless inequitable)