Summary
This Ohio Court of Appeals decision addresses whether a trial court’s judgment terminating child support for one emancipated minor renders the order void ab initio due to the absence of a mandatory child support calculation worksheet. The appellant argued that the failure to include a worksheet violated statutory requirements and precedent. The appellate court held that when child support is terminated for one child while remaining obligations for other children are preserved, the statutory formula automatically adjusts the amount without requiring a new worksheet. Consequently, the trial court’s judgment was affirmed.
Topics
Practice areas
Questions Presented
- Whether the trial court’s termination of child support for an emancipated child is void ab initio because it failed to include a mandatory child support calculation worksheet.
Holdings
- The trial court’s termination of child support for the emancipated child is not void; a new worksheet is not required when the termination is made pursuant to R.C. 3119.89(B) and the existing worksheet remains the basis of the order.
Key quotations
“Because the trial court’s revised child support order was calculated pursuant to R.C. 3119.89(B), the trial court was not required to complete a child support worksheet or make it part of the record.” (¶8)
“A new worksheet is not required.” (¶7)
Factual background
Lyle and Stephanie Bell married in 2003 and had five children. The trial court granted their divorce in 2011 and ordered a shared parenting plan with Stephanie as the child support obligor. After the elder child Jo.J. reached the age of majority, the Child Support Enforcement Agency recommended termination of support for that child, which the trial court adopted in May 2024 without modifying the support order for the younger child.
Procedural history
The trial court terminated child support for the elder child Jo.J. after the child reached the age of majority, adopting the Child Support Enforcement Agency’s recommendation, while leaving the support order for the younger child Je.J. unchanged. Lyle Ray Jones appealed the judgment.
Remand instructions
A special mandate shall be issued directing the Court of Common Pleas, County of Medina, to carry the judgment into execution; a certified copy of this journal entry shall constitute the mandate.