Middendorf v. Middendorf
Supreme Court of Ohio
696 N.E.2d 575 (Ohio 1998)
Max Middendorf owned Middendorf Stockyard Company (MSC) before marrying Pat, and the company's value rose substantially during the marriage while Max actively managed its day-to-day buying and selling decisions. The trial court found the appreciation in MSC's value during the marriage was marital property subject to division, and the court of appeals affirmed; Max appealed, arguing the appreciation stemmed from general increases in the hog market rather than his own labor.
Whether an appreciation in value of separate property is considered marital property in a divorce proceeding if the appreciation was due to the labor, monetary, or in-kind contribution of either or both spouses during the marriage.