Watson v. Minnich

2026-Ohio-1151 · Court of Appeals of Ohio, Fourth Appellate District, Pickaway County · March 20, 2026 · No. 25CA18

Summary

The Ohio Fourth District Court of Appeals affirmed a divorce decree dividing an e-Trade account as marital property. The court held that, because the appellant failed to provide a transcript of the final hearing, it had to presume the regularity and validity of the trial court’s proceedings.

Holdings

  1. Because Husband failed to provide the transcript necessary to review his claim that the trial court improperly classified and divided the e-Trade account, the appellate court was required to presume the regularity and validity of the trial court's proceedings and affirm the judgment.

Questions Presented

  1. Whether the appellate court could review Husband's challenge to the classification and division of the e-Trade account as marital property when Husband failed to provide a transcript of the final divorce hearing.

Disposition

affirmed

Cases Cited (18)

  • Thompson v. Thompson, 2024-Ohio-2147, ¶¶ 32-34 (4th Dist.)(followed)
  • Evans v. Evans, 2014-Ohio-4450, ¶ 26 (4th Dist.)(followed)
  • Barkley v. Barkley, 119 Ohio App.3d 155, 159-161 (4th Dist. 1997)(followed)
  • Wright v. Wright, 1994 WL 649271 (4th Dist. 1994)(followed)
  • C.E. Morris Co. v. Foley Constr. Co., 54 Ohio St. 2d 279 (1978)(followed)
  • In re Jane Doe I, 57 Ohio St.3d 135 (1991)(followed)
  • Seasons Coal Co. v. Cleveland, 10 Ohio St.3d 77 (1984)(followed)
  • Suppan v. Suppan, 2018-Ohio-2569, ¶ 21 (9th Dist.)(followed)
  • Entingh v. Entingh, 2008-Ohio-756, ¶¶ 21-22 (2d Dist.)(followed)
  • Middledorf v. Middledorf, 1998-Ohio-403(followed)

Showing top 10 of 18.

Cited In (0)

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