Ohio Revised Code

Ohio Rev. Code § 2151.231 (2026)

Order requiring support of child without regard to marital status of child's parents

✓ current as of May 2026
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(A) The parent, or caretaker of a child, or the child support enforcement agency of the county in which the child, parent, or caretaker of the child resides may bring an action in a juvenile court or other court with jurisdiction under section 2101.022 or 2301.03 of the Revised Code under this section requesting the court to issue an order requiring a parent of the child to pay an amount for the support of the child without regard to the marital status of the child's parents. No action may be brought under this section against a person presumed to be the parent of a child based on an acknowledgment of paternity that has not yet become final under former section 3111.211 or 5101.314 or section 2151.232, 3111.25, or 3111.821 of the Revised Code.

The parties to an action under this section may raise the issue of the existence or nonexistence of a parent-child relationship, unless a final and enforceable determination of the issue has been made with respect to the parties pursuant to Chapter 3111. of the Revised Code or an acknowledgment of paternity signed by the child's parents has become final pursuant to former section 3111.211 or 5101.314 or section 2151.232, 3111.25, or 3111.821 of the Revised Code. If a complaint is filed under this section and an issue concerning the existence or nonexistence of a parent-child relationship is raised, the court shall treat the action as an action pursuant to sections 3111.01 to 3111.18 of the Revised Code. An order issued in an action under this section does not preclude a party to the action from bringing a subsequent action pursuant to sections 3111.01 to 3111.18 of the Revised Code if the issue concerning the existence or nonexistence of the parent-child relationship was not determined with respect to the party pursuant to a proceeding under this section, a proceeding under Chapter 3111. of the Revised Code, or an acknowledgment of paternity that has become final under former section 3111.211 or 5101.314 or section 2151.232, 3111.25, or 3111.821 of the Revised Code. An order issued pursuant to this section shall remain effective until an order is issued pursuant to sections 3111.01 to 3111.18 of the Revised Code that a parent-child relationship does not exist between the alleged father of the child and the child or until the occurrence of an event described in section 3119.88 of the Revised Code that would require the order to terminate.

The court, in accordance with sections 3119.29 to 3119.56 of the Revised Code, shall include in each support order made under this section the requirement that one or both of the parents provide for the health care needs of the child to the satisfaction of the court.

(B) As used in this section, "caretaker" has the same meaning as in section 3119.01 of the Revised Code.

Last updated April 3, 2024 at 4:09 AM

Notes of Decisions
Cited in 24 cases (9 in the last 5 years), 1994–2026 · leading case: Cuyahoga Cnty. Support Enf't Agency v. Lozada, 657 N.E.2d 372 (Ohio Ct. App. 1995).
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Cuyahoga Cnty. Support Enf't Agency v. Lozada, 657 N.E.2d 372 (Ohio Ct. App. 1995). · cites it 12× “However, in Underwood, the juvenile court dismissed the CSEA on the basis that it was not a proper party to bring the action under R.C. 2151.231. Appellant separately and timely filed its notices of appeal in all five cases.”
State Ex Rel. Lamier v. Lamier, 664 N.E.2d 1384 (Ohio Ct. App. 1995). · cites it 5× “The trial court erred by narrowly construing R.C. 2151.231 and restricting standing to only parents, guardians and custodians.”
In re J.M.G., 2013 Ohio 2693 (Ohio Ct. App. 2013). · cites it 3× “84, a parent who is the subject of an administrative child support order may bring an action under R.C. 2151.231, objecting to the administrative order.”
In re A.D., 2023 Ohio 2442 (Ohio Ct. App. 2023). “23 compare with R.C. 2151.231 and R.C. 3111.111. Indeed, “[a] magistrate’s decision is not effective unless adopted by the court[]” and regardless of “[w]hether or not objections are timely filed, a court may adopt or reject a magistrate’s decision in whole or in part, with or…”
State v. Powell, 2024 Ohio 4923 (Ohio Ct. App. 2024). · cites it 2× “of the Revised Code, actions pursuant to section 2151.231 of the Revised Code, all actions removed from the jurisdiction of the juvenile court pursuant to section 2151.”
In re I.L.J., 2019 Ohio 5241 (Ohio Ct. App. 2019). “84, the father of a child who is the subject of an administrative support order may object to the order by bringing an action in the juvenile court under R.C. 2151.231. An action under R.C. 3111.”
Miano v. Evans, 2022 Ohio 1042 (Ohio Ct. App. 2022). · cites it 15× “84 by filing an action for a child support order under R.C. 2151.231 in the Summit County Court of Common Pleas, Domestic Relations Division.”
In re I.L.J., 2016 Ohio 7052 (Ohio Ct. App. 2016). · cites it 2× “843 provides the procedure for filing objections to an administrative order as follows: The mother or father of a child who is the subject of an administrative support order may object to the order by bringing an action for the payment of support and provision for the child’s…”
Akroyd v. Akroyd, 2024 Ohio 4631 (Ohio Ct. App. 2024). · cites it 2× “of the Revised Code, actions pursuant to section 2151.231 of the Revised Code, all actions removed from the jurisdiction of the juvenile court pursuant to section 2151.”
Perez v. Simkins, 2014 Ohio 4006 (Ohio Ct. App. 2014). · cites it 2× “The last section of that proposed order provided Simkins notice that: In accordance with ORC section 3119.”
Dixon v. Walcutt, 787 N.E.2d 1237 (Ohio Ct. App. 2003). “13(F) does not apply to an action that is brought pursuant to R.C. 2151.231. We disagree. R.C. 3111.01 et seq.”
Craver v. Haefner, 2024 Ohio 2242 (Ohio Ct. App. 2024). “1 1 R.C. 2151.231(A) states, in pertinent part, “The parent * * * of a child * * * may bring an action in a juvenile court or other court with jurisdiction under section 2101.”
Show all 24 citing cases →
Ohio Rev. Code § 2151.231(A): 1 case
Craver v. Haefner, 2024 Ohio 2242 (Ohio Ct. App. 2024). “1 1 R.C. 2151.231(A) states, in pertinent part, “The parent * * * of a child * * * may bring an action in a juvenile court or other court with jurisdiction under section 2101.”
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