Background
Harmony Harper and DeAngelo Lee married in December 2023, separated in October 2024, and had no children. At their November 2025 divorce trial, Harper testified that she owned several properties acquired before the marriage, through inheritance, or with inheritance funds. She also testified that she had paid Lee more than $7,000 for work and supplies related to some of those properties.
Lee sought $54,600 for labor he claimed to have performed on Harper’s properties, asserting that his work created marital active appreciation. He also challenged the trial court’s treatment of a prenuptial agreement, alleged financial misconduct concerning rental-related matters, disputed the application of Ohio’s property-division statute, and objected to cost allocations and case-management rulings.
The Court’s Holding
The Eighth District affirmed the divorce judgment in full. It held that the trial court did not abuse its discretion by declining to award Lee $54,000 for alleged labor because he offered vague testimony without supporting documentation, while Harper presented evidence that she had paid him more than $7,000. The court also held that Harper’s real estate and rental proceeds at issue were separate property, not marital assets subject to division.
The court rejected Lee’s remaining arguments. Although the trial court found the prenuptial agreement invalid, it independently reviewed and divided the parties’ property under R.C. 3105.171. The appellate court found no financial misconduct, no error in the trial court’s use of the marriage dates through the final hearing, and no abuse of discretion in requiring Lee to pay his requested expert’s costs and 60 percent of court costs. Because it found no individual error, it also rejected Lee’s cumulative-error and due-process claim.
Key Takeaways
- A spouse seeking a share of active appreciation in separate property must support the claim with credible evidence connecting labor or other contributions to an increase in value.
- Rental income from traceable separate property remained separate property on this record.
- An invalid prenuptial agreement does not prevent a court from independently conducting the required statutory property-division analysis.
- Trial courts have discretion to allocate divorce-related costs, including costs caused by a party’s requested expert and unnecessary filings.
Why It Matters
The decision illustrates that generalized testimony about work performed on a spouse’s separate property will not necessarily establish a marital interest in appreciation. Evidence of the work, its value, and its causal effect on property value is critical.
It also confirms the broad discretion Ohio domestic-relations courts retain over property division and litigation costs, particularly where the record supports the court’s factual findings and equitable rationale.