Flick v. Flick

In Flick v. Flick, 12th Dist. No. CA2001-05-111, 2001 Ohio 8673, 2001 Ohio App, the court of appeals affirmed the date of the parties' engagement as the de facto commencement of the marriage since they "lived together continuously since their engagement, and pooled their financial resources to maintain a common household, even purchasing property together in anticipation of their retirement." Id. at 5. Conversely, the court of appeals reversed a decision to establish a de facto commencement date where there was "no evidence of any substantial contribution to or investment in the other spouse's separate property prior to the ceremonial marriage."