83 Ohio App. 3d 559 - Layne v. Layne’s Empirical Analysis
1992
Citation profile
92 state decisions
How this case has been cited
Cited by 92 later decisions — most recently September 2023 · most notably 101 Ohio App. 3d 668 - James v. James (1995), 125 Ohio App. 3d 600 - Zeffe v. Zeefe (1998)
92 state decisions
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Relies on Blakemore v. Blakemore · In re Jane Doe 1 · Kunkle v. Kunkle · Kaechele v. Kaechele · Hoyt v. Hoyt
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 92 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[A] retirement plan is an investment made by both spouses during marriage to provide for their later years. They anticipate that the value of the investment will increase with time. At divorce, each spouse is entitled to the value of his or her investment. When the investment has not yet matured, each is entitled to a right to its value at maturity in proportion to the years of marriage. The [non-member] former spouse is not entitled to share in the direct contributions made by the [member] former spouse after divorce. However, the [nonmember] former spouse is entitled to the benefit of any increase in the value of his or her unmatured proportionate share after divorce attributable to the continued participation of the other spouse in the retirement plan. That increase was contemplated when the investment was made. It would be inequitable to deprive the owner of its value. So long as each former spouse is limited to his or her proportionate right to share, there is neither unjust enrichment of the [non-member spouse] nor an inequitable deprivation of his or her rights.”
5 later decisions quote this exact passage“when the amount to be paid can only be determined at the later point of maturity at retirement, a current order should divide and distribute only the right to receive a share of the unmatured pension benefit, reserving determination of exact amounts to the later time when they are known. This method serves both objectives of an equitable division; it disentangles the affairs of the parties while producing an optimum value for each.”
3 later decisions quote this exact passage“trial court must indicate the basis for its award in sufficient detail to enable a reviewing court to determine that the award is fair, equitable and in accordance with the law.”
3 later decisions quote this exact passage
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.