Jones v. Jones

Summary

The Ohio Second District Court of Appeals affirmed a domestic-relations judgment awarding Jeffrey T. Jones statutory interest on the $1,770.46 net property-division judgment, rather than on his entire share of marital civil-settlement proceeds. The court held that interest under R.C. 1343.03(A) applies only to amounts reduced to a definite money judgment and declined to apply the law-of-the-case doctrine because doing so would produce a manifestly unjust result.

Holdings

1. Under R.C. 1343.03(A), statutory interest is available only when money becomes due and payable under a definite money judgment. Because Jeffrey's $201,500 share of the settlement proceeds was not itself reduced to a money judgment payable by Diana, the trial court correctly awarded interest only on the $1,770.46 equalization judgment.
2. The law-of-the-case doctrine is a rule of practice rather than a binding rule of substantive law and will not be applied when doing so would produce an unjust result. Because the prior Jones III remand was incorrect to the extent it suggested interest was due on Jeffrey's entire settlement-proceeds share, adherence to that instruction would result in manifest injustice.

Questions Presented

1. Whether the trial court correctly awarded statutory interest only on the $1,770.46 property-division judgment rather than on Jeffrey's $201,500 share of the marital civil-settlement proceeds.
2. Whether the law-of-the-case doctrine required adherence to the prior remand instruction in Jones III despite the appellate court's conclusion that the instruction was incorrect and that adherence would produce manifest injustice.

Disposition

affirmed