Woods v. Woods, 2018 Ohio 37

Kevin Woods and Alicia Woods divorced in 2012; the decree required sale of the marital residence and division of personal property per an attached exhibit.
Decree allowed either party to reside in and prepare the house for sale after wife vacated; repairs were to be made per mutual agreement or, if no agreement, per the realtors’ advice; reasonable preparation costs to be split equally.
Woods (husband) performed $31,592.54 in repairs/improvements; realtors had approved a subset of repairs (about $21,192.28 approved).
Alicia filed a contempt motion alleging Woods disposed of items awarded to her; Woods sought one-half reimbursement of home repair costs.
Magistrate found Woods in contempt for disposing of certain items, ordered him to reimburse Alicia $5,000 to purge contempt, and denied reimbursement for repairs not approved by realtors; trial court affirmed on objections.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Woods was entitled to reimbursement for one-half of all repairs/improvements to the marital home	Woods: the extra repairs were "required and commonsense" to obtain best sale price; Alicia should pay half	Alicia: only realtor-recommended repairs (per decree) are chargeable; parties bound to realtor advice if no agreement	Court: Affirmed magistrate; Woods not entitled to half of repairs beyond those approved by realtors; denial not an abuse of discretion
Whether Woods’ sale/disposition of items awarded to Alicia constituted contempt and whether $5,000 purge amount was supported	Woods: items were abandoned when Alicia vacated by decree deadline; his actions did not violate the decree; $5,000 unsupported	Alicia: she did not abandon items, attempted to retrieve them, and Woods sold/threw away property without notice; her valuation credible	Court: Affirmed contempt finding and $5,000 purge amount; trial court credited Alicia’s testimony and valuation; contempt proven by evidence and clear/convincing standard

Bisker v. Bisker, 69 Ohio St.3d 608 (trial court has broad discretion in dividing marital property)
Berish v. Berish, 69 Ohio St.2d 318 (standards for review of property division)
Blakemore v. Blakemore, 5 Ohio St.3d 217 (abuse of discretion standard defined)
Cherry v. Cherry, 66 Ohio St.2d 348 (inequality alone does not establish abuse of discretion in property division)
Denovchek v. Trumbull Cty. Bd. of Commrs., 36 Ohio St.3d 14 (definition and scope of contempt)
State v. Chavez–Juarez, 185 Ohio App.3d 189 (discussing civil contempt; remedial/coercive sanctions and standards)
Bishop v. East Ohio Gas Co., 143 Ohio St. 541 (an owner may testify as to value of personal property)