Lousy starter?

Toast

Bread came out of 12 hr hold in fridge laying rather flat and spread out.  Would this be from a weak starter?

You should certainly make sure your starter is freshly fed and grown and not proteolytically liquified from storage before using it.  But a flat loaf is more likely the result of other factors during fermentation that weakened the gluten:  poor gluten development (not enough appropriately gentle folding, etc) or more likely, over-fermentation.  Try to err on the side of underfermentation next time and see if it holds its shape better.  Crumb may not be as open, but loaf should stand taller.  It's a delicate balance and takes experience to develop the right instincts.

Tom