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Ohio Revised Code

Ohio Rev. Code § 3105.18 (2026)

Awarding spousal support - modification of spousal support

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Effective:
March 22, 2013
Latest Legislation:
House Bill 461 - 129th General Assembly
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(A) As used in this section, "spousal support" means any payment or payments to be made to a spouse or former spouse, or to a third party for the benefit of a spouse or a former spouse, that is both for sustenance and for support of the spouse or former spouse. "Spousal support" does not include any payment made to a spouse or former spouse, or to a third party for the benefit of a spouse or former spouse, that is made as part of a division or distribution of property or a distributive award under section 3105.171 of the Revised Code.

(B) In divorce and legal separation proceedings, upon the request of either party and after the court determines the division or disbursement of property under section 3105.171 of the Revised Code, the court of common pleas may award reasonable spousal support to either party. During the pendency of any divorce, or legal separation proceeding, the court may award reasonable temporary spousal support to either party.

An award of spousal support may be allowed in real or personal property, or both, or by decreeing a sum of money, payable either in gross or by installments, from future income or otherwise, as the court considers equitable.

Any award of spousal support made under this section shall terminate upon the death of either party, unless the order containing the award expressly provides otherwise.

(C)(1) In determining whether spousal support is appropriate and reasonable, and in determining the nature, amount, and terms of payment, and duration of spousal support, which is payable either in gross or in installments, the court shall consider all of the following factors:

(a) The income of the parties, from all sources, including, but not limited to, income derived from property divided, disbursed, or distributed under section 3105.171 of the Revised Code;

(b) The relative earning abilities of the parties;

(c) The ages and the physical, mental, and emotional conditions of the parties;

(d) The retirement benefits of the parties;

(e) The duration of the marriage;

(f) The extent to which it would be inappropriate for a party, because that party will be custodian of a minor child of the marriage, to seek employment outside the home;

(g) The standard of living of the parties established during the marriage;

(h) The relative extent of education of the parties;

(i) The relative assets and liabilities of the parties, including but not limited to any court-ordered payments by the parties;

(j) The contribution of each party to the education, training, or earning ability of the other party, including, but not limited to, any party's contribution to the acquisition of a professional degree of the other party;

(k) The time and expense necessary for the spouse who is seeking spousal support to acquire education, training, or job experience so that the spouse will be qualified to obtain appropriate employment, provided the education, training, or job experience, and employment is, in fact, sought;

(l) The tax consequences, for each party, of an award of spousal support;

(m) The lost income production capacity of either party that resulted from that party's marital responsibilities;

(n) Any other factor that the court expressly finds to be relevant and equitable.

(2) In determining whether spousal support is reasonable and in determining the amount and terms of payment of spousal support, each party shall be considered to have contributed equally to the production of marital income.

(D) In an action brought solely for an order for legal separation under section 3105.17 of the Revised Code, any continuing order for periodic payments of money entered pursuant to this section is subject to further order of the court upon changed circumstances of either party.

(E) If a continuing order for periodic payments of money as alimony is entered in a divorce or dissolution of marriage action that is determined on or after May 2, 1986, and before January 1, 1991, or if a continuing order for periodic payments of money as spousal support is entered in a divorce or dissolution of marriage action that is determined on or after January 1, 1991, the court that enters the decree of divorce or dissolution of marriage does not have jurisdiction to modify the amount or terms of the alimony or spousal support unless the court determines that the circumstances of either party have changed and unless one of the following applies:

(1) In the case of a divorce, the decree or a separation agreement of the parties to the divorce that is incorporated into the decree contains a provision specifically authorizing the court to modify the amount or terms of alimony or spousal support.

(2) In the case of a dissolution of marriage, the separation agreement that is approved by the court and incorporated into the decree contains a provision specifically authorizing the court to modify the amount or terms of alimony or spousal support.

(F)(1) For purposes of divisions (D) and (E) of this section and subject to division (F)(2) of this section, a change in the circumstances of a party includes, but is not limited to, any increase or involuntary decrease in the party's wages, salary, bonuses, living expenses, or medical expenses, or other changed circumstances so long as both of the following apply:

(a) The change in circumstances is substantial and makes the existing award no longer reasonable and appropriate.

(b) The change in circumstances was not taken into account by the parties or the court as a basis for the existing award when it was established or last modified, whether or not the change in circumstances was forseeable.

(2) In determining whether to modify an existing order for spousal support, the court shall consider any purpose expressed in the initial order or award and enforce any voluntary agreement of the parties. Absent an agreement of the parties, the court shall not modify the continuing jurisdiction of the court as contained in the original decree.

(G) If any person required to pay alimony under an order made or modified by a court on or after December 1, 1986, and before January 1, 1991, or any person required to pay spousal support under an order made or modified by a court on or after January 1, 1991, is found in contempt of court for failure to make alimony or spousal support payments under the order, the court that makes the finding, in addition to any other penalty or remedy imposed, shall assess all court costs arising out of the contempt proceeding against the person and shall require the person to pay any reasonable attorney's fees of any adverse party, as determined by the court, that arose in relation to the act of contempt.
Notes of Decisions
Cited in 1,014 cases (193 in the last 5 years), 1953–2026 · leading case: Morris v. Morris (Slip Opinion), 2016-Ohio-5002, 69 N.E.3d 664.
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Morris v. Morris (Slip Opinion), 2016-Ohio-5002, 69 N.E.3d 664. · cites it 72× “{¶ 31} In Crouser, this court held that R.C. 3105.18 is the substantive law that controls whether a trial court has authority to modify an award of spousal support.”
Mandelbaum v. Mandelbaum, 2009-Ohio-1222, 905 N.E.2d 172. · cites it 23× “21773, 2004-Ohio-3844 , 2004 WL 1620723 , relying on amendments to R.C. 3105.18, held that trial courts have jurisdiction to modify an award of spousal support based on “any” change in circumstances rather than a substantial change.”
Organ v. Organ, 2014-Ohio-3474, 17 N.E.3d 1192. · cites it 38× “It reasoned that, if sustenance means to sustain, the upper limit of spousal support that can be awarded in a case is the amount that is needed to allow the recipient spouse to maintain the marital standard of living.”
Collins v. Collins, 2011-Ohio-2087. · cites it 21× “Unlike the child support statute, there is no language in R.C. 3105.18 that directs the trial court to “impute” income.”
Schwieterman v. Schwieterman, 2020-Ohio-4881. · cites it 23× “Legal Standard {¶68} R.C. 3105.18 governs the award of spousal support in divorce cases.”
Salpietro v. Salpietro, 2023-Ohio-169, 205 N.E.3d 1203. · cites it 16× “{¶ 30} The trial court cannot consider any single R.C. 3105.18(C) factor in isolation. Kaechele at paragraph one of the syllabus.”
Falah v. Falah, 2017-Ohio-1087, 87 N.E.3d 763. · cites it 19× “” R.C. 3105.18(B). Absent a challenge to a particular factual finding of the trial court, this Court “‘reviews a spousal support award under an abuse of discretion standard.”
Bowen v. Bowen, 725 N.E.2d 1165 (Ohio Ct. App. 9th Dist. 1999). · cites it 13× “While need was previously considered under the old statutory scheme, this court has made clear “that under R.C. 3105.18, as modified in April 1991, ‘need’ is no longer the basis for a spousal support award.”
Smoyer v. Smoyer, 2019-Ohio-3461. · cites it 16× “{¶ 18} Regarding spousal support, the trial court conducted an analysis pursuant to R.C. 3105.18. The court considered Chloe's age and health, the length of the marriage, Chloe's present employability, the labor market, the ease of obtaining licensure as a registered nurse or…”
Kaechele v. Kaechele, 518 N.E.2d 1197 (Ohio 1988). · cites it 8× “I In the case sub judice, the court of *95 appeals held that R.C. 3105.18 1 “* * * mandates consideration of the standard of living of the parties established during the marriage with the apparent intent to have both parties maintain the standard of living established during the…”
Buckles v. Buckles, 546 N.E.2d 950 (Ohio Ct. App. 10th Dist. 1988). · cites it 14× “2 This especially is required with regard to property expressly referred to in R.C. 3105.18, whether or not that property is specifically set aside to be divided.”
Oatey v. Oatey, 614 N.E.2d 1054 (Ohio Ct. App. 8th Dist. 1992). · cites it 19× “” Defendant’s brief in opposition argues the “Order” for interim attorney fees was entered pursuant to R.C. 3105.18(H) and constitutes a final appealable order affecting a “substantial right” made in a “special proceeding” within the scope of R.”
Show all 1,014 citing cases →
Ohio Rev. Code § 3105.18(0X1): 1 case
Cassavore v. Cassavore, 1 Ohio App. Unrep. 232 (Ohio Ct. App. 6th Dist. 1990).
Ohio Rev. Code § 3105.18(A): 62 cases
Palazzo v. Palazzo, 2016-Ohio-3041.
Organ v. Organ, 2014-Ohio-3474, 17 N.E.3d 1192. “It reasoned that, if sustenance means to sustain, the upper limit of spousal support that can be awarded in a case is the amount that is needed to allow the recipient spouse to maintain the marital standard of living.”
McCoy v. McCoy, 632 N.E.2d 1358 (Ohio Ct. App. 8th Dist. 1993).
Frost v. Frost, 618 N.E.2d 198 (Ohio Ct. App. 10th Dist. 1992).
Corwin v. Corwin, 2013-Ohio-3996.
Ohio Rev. Code § 3105.18(A)(7): 1 case
Josselson v. Josselson, 557 N.E.2d 835 (Ohio Ct. App. 8th Dist. 1988).
Ohio Rev. Code § 3105.18(B): 254 cases
Thomasson v. Thomasson (Slip Opinion), 2018-Ohio-2417, 106 N.E.3d 1239.
Waller v. Waller, 837 N.E.2d 843 (Ohio Ct. App. 7th Dist. 2005).
Kaechele v. Kaechele, 518 N.E.2d 1197 (Ohio 1988). “I In the case sub judice, the court of *95 appeals held that R.C. 3105.18 1 “* * * mandates consideration of the standard of living of the parties established during the marriage with the apparent intent to have both parties maintain the standard of living established during the…”
Buckles v. Buckles, 546 N.E.2d 950 (Ohio Ct. App. 10th Dist. 1988). “2 This especially is required with regard to property expressly referred to in R.C. 3105.18, whether or not that property is specifically set aside to be divided.”
Theriot v. Hetrick, 2020-Ohio-6995.
Ohio Rev. Code § 3105.18(B)(1): 7 cases
Bingham v. Bingham, 459 N.E.2d 231 (Ohio Ct. App. 10th Dist. 1983).
Leighner v. Leighner, 515 N.E.2d 625 (Ohio Ct. App. 10th Dist. 1986).
Josselson v. Josselson, 557 N.E.2d 835 (Ohio Ct. App. 8th Dist. 1988).
Ranz v. Ranz, 554 N.E.2d 142 (Ohio Ct. App. 1st Dist. 1988).
Blair v. Blair, 463 N.E.2d 423 (Ohio Ct. App. 10th Dist. 1983).
Ohio Rev. Code § 3105.18(B)(10): 3 cases
Kahn v. Kahn, 536 N.E.2d 678 (Ohio Ct. App. 2d Dist. 1987).
Sanzenbacher v. Sanzenbacher, 444 N.E.2d 454 (Ohio Ct. App. 6th Dist. 1981).
Carpenter v. Carpenter, 573 N.E.2d 698 (Ohio Ct. App. 9th Dist. 1988).
Ohio Rev. Code § 3105.18(B)(11): 1 case
Gross v. Gross, 464 N.E.2d 500 (Ohio 1984).
Ohio Rev. Code § 3105.18(B)(2): 4 cases
Babka v. Babka, 615 N.E.2d 247 (Ohio Ct. App. 9th Dist. 1992).
Mottice v. Mottice, 693 N.E.2d 1179 (Ohio Ct. App. 9th Dist. 1997).
Haninger v. Haninger, 456 N.E.2d 1228 (Ohio Ct. App. 10th Dist. 1982).
Reichert v. Reichert, 491 N.E.2d 376 (Ohio Ct. App. 9th Dist. 1985).
Ohio Rev. Code § 3105.18(B)(3): 8 cases
Bisker v. Bisker, 635 N.E.2d 308 (Ohio 1994).
Lemon v. Lemon, 537 N.E.2d 246 (Ohio Ct. App. 4th Dist. 1988).
Mottice v. Mottice, 693 N.E.2d 1179 (Ohio Ct. App. 9th Dist. 1997).
Stevens v. Stevens, 492 N.E.2d 131 (Ohio 1986).
Blair v. Blair, 463 N.E.2d 423 (Ohio Ct. App. 10th Dist. 1983).
Ohio Rev. Code § 3105.18(B)(4): 5 cases
Kaechele v. Kaechele, 518 N.E.2d 1197 (Ohio 1988). “I In the case sub judice, the court of *95 appeals held that R.C. 3105.18 1 “* * * mandates consideration of the standard of living of the parties established during the marriage with the apparent intent to have both parties maintain the standard of living established during the…”
Stevens v. Stevens, 492 N.E.2d 131 (Ohio 1986).
Nori v. Nori, 568 N.E.2d 730 (Ohio Ct. App. 12th Dist. 1989).
Gore v. Gore, 499 N.E.2d 1281 (Ohio Ct. App. 9th Dist. 1985).
Edwards v. Edwards, 2019-Ohio-5413, 151 N.E.3d 6.
Ohio Rev. Code § 3105.18(B)(6): 2 cases
Goode v. Goode, 590 N.E.2d 439 (Ohio Ct. App. 10th Dist. 1991).
Haninger v. Haninger, 456 N.E.2d 1228 (Ohio Ct. App. 10th Dist. 1982).
Ohio Rev. Code § 3105.18(B)(7): 4 cases
Stevens v. Stevens, 492 N.E.2d 131 (Ohio 1986).
Kahn v. Kahn, 536 N.E.2d 678 (Ohio Ct. App. 2d Dist. 1987).
Haninger v. Haninger, 456 N.E.2d 1228 (Ohio Ct. App. 10th Dist. 1982).
Gross v. Gross, 582 N.E.2d 1144 (Ohio Ct. App. 10th Dist. 1990).
Ohio Rev. Code § 3105.18(B)(9): 2 cases
Josselson v. Josselson, 557 N.E.2d 835 (Ohio Ct. App. 8th Dist. 1988).
Pacht v. Jadd, 469 N.E.2d 918 (Ohio Ct. App. 10th Dist. 1983).
Ohio Rev. Code § 3105.18(BX1): 1 case
Smith v. Smith, 1 Ohio App. Unrep. 201 (Ohio Ct. App. 6th Dist. 1990).
Ohio Rev. Code § 3105.18(BX7): 1 case
Gross v. Gross, 582 N.E.2d 1144 (Ohio Ct. App. 10th Dist. 1990).
Ohio Rev. Code § 3105.18(C): 236 cases
Norbut v. Norbut (In Re Norbut), 387 B.R. 199 (Bankr. S.D. Ohio 2008).
Hunter v. Troutman, 2025-Ohio-366, 264 N.E.3d 305.
Rodgers v. Rodgers, 2017-Ohio-7886.
Organ v. Organ, 2014-Ohio-3474, 17 N.E.3d 1192. “It reasoned that, if sustenance means to sustain, the upper limit of spousal support that can be awarded in a case is the amount that is needed to allow the recipient spouse to maintain the marital standard of living.”
Dach v. Homewood, 2015-Ohio-4191.
Ohio Rev. Code § 3105.18(C)(1): 430 cases
Salpietro v. Salpietro, 2023-Ohio-169, 205 N.E.3d 1203. “{¶ 30} The trial court cannot consider any single R.C. 3105.18(C) factor in isolation. Kaechele at paragraph one of the syllabus.”
Hunley v. Hunley, 2020-Ohio-5053.
Walpole v. Walpole, 2013-Ohio-3529.
Kokoski v. Kokoski, 2013-Ohio-3567.
Organ v. Organ, 2014-Ohio-3474, 17 N.E.3d 1192. “It reasoned that, if sustenance means to sustain, the upper limit of spousal support that can be awarded in a case is the amount that is needed to allow the recipient spouse to maintain the marital standard of living.”
Ohio Rev. Code § 3105.18(C)(1)(A): 1 case
Kachmar v. Kachmar, 2010-Ohio-1311.
Ohio Rev. Code § 3105.18(C)(1)(L): 1 case
Lam v. Lam, 2012-Ohio-4885.
Ohio Rev. Code § 3105.18(C)(1)(Z): 1 case
Frost v. Frost, 618 N.E.2d 198 (Ohio Ct. App. 10th Dist. 1992).
Ohio Rev. Code § 3105.18(C)(1)(a): 208 cases
Mahoney v. Mahoney, 2017-Ohio-7917.
Reveal v. Reveal, 798 N.E.2d 1132 (Ohio Ct. App. 2d Dist. 2003).
Hunley v. Hunley, 2020-Ohio-5053.
Organ v. Organ, 2014-Ohio-3474, 17 N.E.3d 1192. “It reasoned that, if sustenance means to sustain, the upper limit of spousal support that can be awarded in a case is the amount that is needed to allow the recipient spouse to maintain the marital standard of living.”
Kim v. Kim, 2020-Ohio-22, 150 N.E.3d 1229.
Ohio Rev. Code § 3105.18(C)(1)(b): 39 cases
Kokoski v. Kokoski, 2013-Ohio-3567.
Spillane v. Spillane, 2020-Ohio-5052.
Berthelot v. Berthelot, 796 N.E.2d 541 (Ohio Ct. App. 9th Dist. 2003).
Smoyer v. Smoyer, 2019-Ohio-3461. “{¶ 18} Regarding spousal support, the trial court conducted an analysis pursuant to R.C. 3105.18. The court considered Chloe's age and health, the length of the marriage, Chloe's present employability, the labor market, the ease of obtaining licensure as a registered nurse or…”
Walpole v. Walpole, 2013-Ohio-3529.
Ohio Rev. Code § 3105.18(C)(1)(c): 25 cases
Torres Friedenberg v. Friedenberg (Slip Opinion), 2020-Ohio-3345, 161 N.E.3d 546.
Smoyer v. Smoyer, 2019-Ohio-3461. “{¶ 18} Regarding spousal support, the trial court conducted an analysis pursuant to R.C. 3105.18. The court considered Chloe's age and health, the length of the marriage, Chloe's present employability, the labor market, the ease of obtaining licensure as a registered nurse or…”
Babka v. Babka, 615 N.E.2d 247 (Ohio Ct. App. 9th Dist. 1992).
Mahoney v. Mahoney, 2017-Ohio-7917.
Gentile v. Gentile, 2013-Ohio-1338.
Ohio Rev. Code § 3105.18(C)(1)(d): 17 cases
Chattree v. Chattree, 2014-Ohio-489, 8 N.E.3d 390.
Gentile v. Gentile, 2013-Ohio-1338.
Falah v. Falah, 2017-Ohio-1087, 87 N.E.3d 763. “” R.C. 3105.18(B). Absent a challenge to a particular factual finding of the trial court, this Court “‘reviews a spousal support award under an abuse of discretion standard.”
Schwieterman v. Schwieterman, 2020-Ohio-4881. “Legal Standard {¶68} R.C. 3105.18 governs the award of spousal support in divorce cases.”
Heimann v. Heimann, 2022-Ohio-241.
Ohio Rev. Code § 3105.18(C)(1)(e): 16 cases
La Spisa v. La Spisa, 2023-Ohio-3467, 225 N.E.3d 398.
Schwieterman v. Schwieterman, 2020-Ohio-4881. “Legal Standard {¶68} R.C. 3105.18 governs the award of spousal support in divorce cases.”
Heimann v. Heimann, 2022-Ohio-241.
Verma v. Verma, 903 N.E.2d 343 (Ohio Ct. App. 2d Dist. 2008).
Ernsberger v. Ernsberger, 2014-Ohio-4470.
Ohio Rev. Code § 3105.18(C)(1)(e)(f): 1 case
Parsons v. Parsons, 2025-Ohio-2511.
Ohio Rev. Code § 3105.18(C)(1)(f): 8 cases
Schwieterman v. Schwieterman, 2020-Ohio-4881. “Legal Standard {¶68} R.C. 3105.18 governs the award of spousal support in divorce cases.”
Heimann v. Heimann, 2022-Ohio-241.
Bowen v. Thomas, 656 N.E.2d 1328 (Ohio Ct. App. 3d Dist. 1995).
Ernsberger v. Ernsberger, 2014-Ohio-4470.
Thomasson v. Thomasson, 2020-Ohio-3890.
Ohio Rev. Code § 3105.18(C)(1)(g): 23 cases
Schwieterman v. Schwieterman, 2020-Ohio-4881. “Legal Standard {¶68} R.C. 3105.18 governs the award of spousal support in divorce cases.”
Mahoney v. Mahoney, 2017-Ohio-7917.
Smoyer v. Smoyer, 2019-Ohio-3461. “{¶ 18} Regarding spousal support, the trial court conducted an analysis pursuant to R.C. 3105.18. The court considered Chloe's age and health, the length of the marriage, Chloe's present employability, the labor market, the ease of obtaining licensure as a registered nurse or…”
Washek v. Washek, 2019-Ohio-1504.
Falah v. Falah, 2017-Ohio-1087, 87 N.E.3d 763. “” R.C. 3105.18(B). Absent a challenge to a particular factual finding of the trial court, this Court “‘reviews a spousal support award under an abuse of discretion standard.”
Ohio Rev. Code § 3105.18(C)(1)(h): 6 cases
Heimann v. Heimann, 2022-Ohio-241.
Ernsberger v. Ernsberger, 2014-Ohio-4470.
Machesky v. Machesky, 2011-Ohio-862.
MacDonald v. MacDonald, 2011-Ohio-5389.
Shetler v. Shetler, 2013-Ohio-5860.
Ohio Rev. Code § 3105.18(C)(1)(i): 48 cases
Falah v. Falah, 2017-Ohio-1087, 87 N.E.3d 763. “” R.C. 3105.18(B). Absent a challenge to a particular factual finding of the trial court, this Court “‘reviews a spousal support award under an abuse of discretion standard.”
Bobie v. Bobie, 2023-Ohio-3293.
Palazzo v. Palazzo, 2016-Ohio-3041.
Passyalia v. Moneir, 2017-Ohio-7033, 95 N.E.3d 723.
Daugherty v. Daugherty, 2013-Ohio-1934.
Ohio Rev. Code § 3105.18(C)(1)(j): 10 cases
Stratton v. Stratton, 2019-Ohio-3279.
Salpietro v. Salpietro, 2023-Ohio-169, 205 N.E.3d 1203. “{¶ 30} The trial court cannot consider any single R.C. 3105.18(C) factor in isolation. Kaechele at paragraph one of the syllabus.”
Falah v. Falah, 2017-Ohio-1087, 87 N.E.3d 763. “” R.C. 3105.18(B). Absent a challenge to a particular factual finding of the trial court, this Court “‘reviews a spousal support award under an abuse of discretion standard.”
Schwieterman v. Schwieterman, 2020-Ohio-4881. “Legal Standard {¶68} R.C. 3105.18 governs the award of spousal support in divorce cases.”
Heimann v. Heimann, 2022-Ohio-241.
Ohio Rev. Code § 3105.18(C)(1)(k): 6 cases
Schwieterman v. Schwieterman, 2020-Ohio-4881. “Legal Standard {¶68} R.C. 3105.18 governs the award of spousal support in divorce cases.”
Smoyer v. Smoyer, 2019-Ohio-3461. “{¶ 18} Regarding spousal support, the trial court conducted an analysis pursuant to R.C. 3105.18. The court considered Chloe's age and health, the length of the marriage, Chloe's present employability, the labor market, the ease of obtaining licensure as a registered nurse or…”
Heimann v. Heimann, 2022-Ohio-241.
Boney v. Boney, 2010-Ohio-4245.
Muckensturm v. Muckensturm, 2012-Ohio-3062.
Ohio Rev. Code § 3105.18(C)(1)(l): 16 cases
Schuh v. Schuh, 2014-Ohio-4755.
Spillane v. Spillane, 2020-Ohio-5052.
La Spisa v. La Spisa, 2023-Ohio-3467, 225 N.E.3d 398.
Nelson v. Nelson, 2022-Ohio-658.
Smoyer v. Smoyer, 2019-Ohio-3461. “{¶ 18} Regarding spousal support, the trial court conducted an analysis pursuant to R.C. 3105.18. The court considered Chloe's age and health, the length of the marriage, Chloe's present employability, the labor market, the ease of obtaining licensure as a registered nurse or…”
Ohio Rev. Code § 3105.18(C)(1)(m): 10 cases
Smoyer v. Smoyer, 2019-Ohio-3461. “{¶ 18} Regarding spousal support, the trial court conducted an analysis pursuant to R.C. 3105.18. The court considered Chloe's age and health, the length of the marriage, Chloe's present employability, the labor market, the ease of obtaining licensure as a registered nurse or…”
Falah v. Falah, 2017-Ohio-1087, 87 N.E.3d 763. “” R.C. 3105.18(B). Absent a challenge to a particular factual finding of the trial court, this Court “‘reviews a spousal support award under an abuse of discretion standard.”
Clifford v. Skaggs, 2017-Ohio-8597.
Saks v. Riga, 2014-Ohio-4930.
Heimann v. Heimann, 2022-Ohio-241.
Ohio Rev. Code § 3105.18(C)(1)(n): 61 cases
Collins v. Collins, 2011-Ohio-2087. “Unlike the child support statute, there is no language in R.C. 3105.18 that directs the trial court to “impute” income.”
Choi v. Choi, 2018-Ohio-725, 106 N.E.3d 908.
Kapadia v. Kapadia, 2011-Ohio-2255.
Rucks v. Moore, 2018-Ohio-4692.
Salpietro v. Salpietro, 2023-Ohio-169, 205 N.E.3d 1203. “{¶ 30} The trial court cannot consider any single R.C. 3105.18(C) factor in isolation. Kaechele at paragraph one of the syllabus.”
Ohio Rev. Code § 3105.18(C)(2): 14 cases
Organ v. Organ, 2014-Ohio-3474, 17 N.E.3d 1192. “It reasoned that, if sustenance means to sustain, the upper limit of spousal support that can be awarded in a case is the amount that is needed to allow the recipient spouse to maintain the marital standard of living.”
C.S. v. M.S., 2019-Ohio-1876.
Hutta v. Hutta, 894 N.E.2d 1282 (Ohio Ct. App. 5th Dist. 2008).
Nguyen v. Coy, 2017-Ohio-4164.
Collins v. Collins, 2011-Ohio-2087. “Unlike the child support statute, there is no language in R.C. 3105.18 that directs the trial court to “impute” income.”
Ohio Rev. Code § 3105.18(C)(a): 1 case
Salameh v. Salameh, 2019-Ohio-5390.
Ohio Rev. Code § 3105.18(C)(b): 2 cases
Mahoney v. Mahoney, 2017-Ohio-7917.
Muckensturm v. Muckensturm, 2012-Ohio-3062.
Ohio Rev. Code § 3105.18(C)(d): 1 case
Muckensturm v. Muckensturm, 2012-Ohio-3062.
Ohio Rev. Code § 3105.18(C)(l): 2 cases
Hawbecker v. Hawbecker, 2016-Ohio-5740.
Kohn v. Kohn, 2025-Ohio-1052.
Ohio Rev. Code § 3105.18(C)(l)(i): 1 case
Glassner v. Glassner, 828 N.E.2d 642 (Ohio Ct. App. 5th Dist. 2005).
Ohio Rev. Code § 3105.18(C)(l)(k): 1 case
Goode v. Goode, 590 N.E.2d 439 (Ohio Ct. App. 10th Dist. 1991).
Ohio Rev. Code § 3105.18(C)(l)(n): 4 cases
Moore v. Moore, 613 N.E.2d 1097 (Ohio Ct. App. 9th Dist. 1992).
Krisher v. Krisher, 611 N.E.2d 499 (Ohio Ct. App. 3d Dist. 1992).
Apt v. Apt, 947 N.E.2d 1317 (Ohio Ct. App. 2d Dist. 2011).
Ghai v. Ghai, 913 N.E.2d 508 (Ohio Ct. App. 12th Dist. 2009).
Ohio Rev. Code § 3105.18(D): 18 cases
Morris v. Morris (Slip Opinion), 2016-Ohio-5002, 69 N.E.3d 664. “{¶ 31} In Crouser, this court held that R.C. 3105.18 is the substantive law that controls whether a trial court has authority to modify an award of spousal support.”
Barton v. Barton, 2017-Ohio-980.
Mandelbaum v. Mandelbaum, 2009-Ohio-1222, 905 N.E.2d 172. “21773, 2004-Ohio-3844 , 2004 WL 1620723 , relying on amendments to R.C. 3105.18, held that trial courts have jurisdiction to modify an award of spousal support based on “any” change in circumstances rather than a substantial change.”
Condit v. Condit, 943 N.E.2d 1041 (Ohio Ct. App. 1st Dist. 2010).
Okos v. Okos, 739 N.E.2d 368 (Ohio Ct. App. 6th Dist. 2000).
Ohio Rev. Code § 3105.18(D)(1): 3 cases
Gullia v. Gullia, 639 N.E.2d 822 (Ohio Ct. App. 8th Dist. 1994).
Merkle v. Merkle, 686 N.E.2d 316 (Ohio Ct. App. 7th Dist. 1996).
Meinke v. Meinke, 565 N.E.2d 875 (Ohio Ct. App. 6th Dist. 1989).
Ohio Rev. Code § 3105.18(D)(2): 3 cases
Morris v. Morris (Slip Opinion), 2016-Ohio-5002, 69 N.E.3d 664. “{¶ 31} In Crouser, this court held that R.C. 3105.18 is the substantive law that controls whether a trial court has authority to modify an award of spousal support.”
Colley v. Colley, 538 N.E.2d 410 (Ohio 1989).
In re Adams, 543 N.E.2d 797 (Ohio 1989).
Ohio Rev. Code § 3105.18(DX1): 1 case
Cassavore v. Cassavore, 1 Ohio App. Unrep. 232 (Ohio Ct. App. 6th Dist. 1990).
Ohio Rev. Code § 3105.18(E): 137 cases
Morris v. Morris (Slip Opinion), 2016-Ohio-5002, 69 N.E.3d 664. “{¶ 31} In Crouser, this court held that R.C. 3105.18 is the substantive law that controls whether a trial court has authority to modify an award of spousal support.”
Kimble v. Kimble, 2002-Ohio-6667, 97 Ohio St. 3d 424.
Kimble v. Kimble, 780 N.E.2d 273 (Ohio 2002).
Barton v. Barton, 2017-Ohio-980.
Reveal v. Reveal, 798 N.E.2d 1132 (Ohio Ct. App. 2d Dist. 2003).
Ohio Rev. Code § 3105.18(E)(1): 49 cases
Smoyer v. Smoyer, 2019-Ohio-3461. “{¶ 18} Regarding spousal support, the trial court conducted an analysis pursuant to R.C. 3105.18. The court considered Chloe's age and health, the length of the marriage, Chloe's present employability, the labor market, the ease of obtaining licensure as a registered nurse or…”
Joseph v. Joseph, 702 N.E.2d 949 (Ohio Ct. App. 2d Dist. 1997).
Berthelot v. Berthelot, 796 N.E.2d 541 (Ohio Ct. App. 9th Dist. 2003).
Bowen v. Bowen, 725 N.E.2d 1165 (Ohio Ct. App. 9th Dist. 1999). “While need was previously considered under the old statutory scheme, this court has made clear “that under R.C. 3105.18, as modified in April 1991, ‘need’ is no longer the basis for a spousal support award.”
Rohlman v. Rohlman, 2018-Ohio-1543, 110 N.E.3d 1006.
Ohio Rev. Code § 3105.18(E)(2): 16 cases
Apt v. Apt, 947 N.E.2d 1317 (Ohio Ct. App. 2d Dist. 2011).
Walsh v. Walsh, 2022-Ohio-3373.
Thomas v. Thomas, 825 N.E.2d 626 (Ohio Ct. App. 11th Dist. 2004).
Tedrick v. Tedrick, 2016-Ohio-1488.
Miller v. Miller, 2022-Ohio-1493.
Ohio Rev. Code § 3105.18(F): 79 cases
Pietrantano v. Pietrantano, 2013-Ohio-4330.
Tsai v. Tien, 832 N.E.2d 809 (Ohio Ct. App. 5th Dist. 2005).
Mandelbaum v. Mandelbaum, 2009-Ohio-1222, 905 N.E.2d 172. “21773, 2004-Ohio-3844 , 2004 WL 1620723 , relying on amendments to R.C. 3105.18, held that trial courts have jurisdiction to modify an award of spousal support based on “any” change in circumstances rather than a substantial change.”
Kucmanic v. Kucmanic, 695 N.E.2d 1205 (Ohio Ct. App. 8th Dist. 1997).
Bowen v. Bowen, 725 N.E.2d 1165 (Ohio Ct. App. 9th Dist. 1999). “While need was previously considered under the old statutory scheme, this court has made clear “that under R.C. 3105.18, as modified in April 1991, ‘need’ is no longer the basis for a spousal support award.”
Ohio Rev. Code § 3105.18(F)(1): 36 cases
Stevens v. Stevens, 2018-Ohio-2662.
Simon v. Simon, 2021-Ohio-1387.
Daubenmire v. Daubenmire, 2019-Ohio-2372.
Pietrantano v. Pietrantano, 2013-Ohio-4330.
Cox v. Cox, 2017-Ohio-1010.
Ohio Rev. Code § 3105.18(F)(1)(a): 20 cases
Bixler v. Bixler, 2017-Ohio-7022.
Cox v. Cox, 2017-Ohio-1010.
DiPasquale v. DiPasquale, 2016-Ohio-8457.
Schroer v. Schroer, 2020-Ohio-62.
Barry v. White, 2023-Ohio-1570.
Ohio Rev. Code § 3105.18(F)(1)(b): 11 cases
Tedrick v. Tedrick, 2016-Ohio-1488.
Barry v. White, 2023-Ohio-1570.
Loewe v. Loewe, 2024-Ohio-323.
Patti v. Patti, 2014-Ohio-1156.
Ogle v. Ogle, 2018-Ohio-5141, 128 N.E.3d 775.
Ohio Rev. Code § 3105.18(F)(2): 17 cases
Barry v. White, 2023-Ohio-1570.
Simon v. Simon, 2021-Ohio-1387.
Kolenz v. Kolenz, 2013-Ohio-3605.
Talley v. Talley, 2016-Ohio-3533.
Salvato v. Salvato, 2013-Ohio-5268, 2 N.E.3d 974.
Ohio Rev. Code § 3105.18(F)(b): 1 case
Branden v. Branden, 2017-Ohio-7477.
Ohio Rev. Code § 3105.18(G): 18 cases
Szymczak v. Szymczak, 737 N.E.2d 980 (Ohio Ct. App. 8th Dist. 2000).
Tretola v. Tretola, 2014-Ohio-5484.
Dean v. Dean, 2011-Ohio-2401.
Simon v. Simon, 2021-Ohio-1387.
Rhea v. Rhea, 2017-Ohio-4141.
Ohio Rev. Code § 3105.18(H): 47 cases
Oatey v. Oatey, 614 N.E.2d 1054 (Ohio Ct. App. 8th Dist. 1992). “” Defendant’s brief in opposition argues the “Order” for interim attorney fees was entered pursuant to R.C. 3105.18(H) and constitutes a final appealable order affecting a “substantial right” made in a “special proceeding” within the scope of R.”
Allan v. Allan, 2019-Ohio-2111.
Bradley v. Bradley, 2021-Ohio-2514.
Hess v. Riedel-Hess, 794 N.E.2d 96 (Ohio Ct. App. 10th Dist. 2003).
Groza-Vance v. Vance, 834 N.E.2d 15 (Ohio Ct. App. 10th Dist. 2005).
Ohio Rev. Code § 3105.18(S): 1 case
Bevens v. Bevens, 6 Ohio App. Unrep. 171 (Ohio Ct. App. 6th Dist. 1990).
Ohio Rev. Code § 3105.18(a): 1 case
Branden v. Branden, 2017-Ohio-7477.
Ohio Rev. Code § 3105.18(a)(b)(c)(d): 1 case
Clifford v. Skaggs, 2017-Ohio-8597.
Ohio Rev. Code § 3105.18(c)(1): 3 cases
Buzard v. Buzard, 2012-Ohio-2658.
Hittle v. Hittle, 910 N.E.2d 1042 (Ohio Ct. App. 2d Dist. 2009).
Dolan v. Dolan, 2011-Ohio-5195.
Ohio Rev. Code § 3105.18(c)(1)(i): 1 case
Fordyce v. Fordyce, 2011-Ohio-3406.
Ohio Rev. Code § 3105.18(e)(1): 1 case
Williams v. Williams, 2016-Ohio-7595.
Ohio Rev. Code § 3105.18(e)(l): 1 case
Quinn v. Quinn, 2022-Ohio-3643.
Ohio Rev. Code § 3105.18(l): 1 case
Levy v. Levy, 2014-Ohio-2650.
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.