Ohio Revised Code

Ohio Rev. Code § 3105.61 (2026)

Jurisdiction

✓ current as of May 2026
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The court of common pleas may grant a dissolution of marriage.

Notes of Decisions
Cited in 16 cases, 1981–2017 · leading case: In Re Murphy, 461 N.E.2d 910 (Ohio Ct. App. 1983).
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In Re Murphy, 461 N.E.2d 910 (Ohio Ct. App. 1983). · cites it 4× “This appeal presents two questions about a decree of dissolution granted under R.C. 3105.61 et seq., when without the knowledge or agreement of one spouse, the separation agreement fails to disclose and provide for substantial and material assets owned by the other spouse: (1)…”
Ashley v. Ashley, 439 N.E.2d 911 (Ohio Ct. App. 1981). · cites it 4× “This action for dissolution of marriage was brought under the special statutory proceedings embodied in R.C. 3105.61 to 3105.65. 3 Examining these re *82 cent statutes, it is evident that they require agreement between the husband and wife on both elements of the proceedings.”
Anderson v. Anderson, 468 N.E.2d 784 (Ohio Ct. App. 1984). · cites it 3× “This conclusion is inescapable in light of the fact that mutual consent to a separation agreement is a prerequisite to a valid judgment of dissolution pursuant to R.C. 3105.61 et seq. To vacate one without vacating the other would be repugnant to the purposes of the legislation.”
Gross v. Gross, 464 N.E.2d 500 (Ohio 1984). “, provides for the dissolution of the marriage by agreement of the parties which is a form of “no fault” divorce, but it requires a written agreement of the parties regarding custody of any children of the parties, child support, visitation rights, alimony and property division.”
In Re Dissolution of Marriage of Seders, 536 N.E.2d 1190 (Ohio Ct. App. 1987). “R.C. 3105.61 et seq. and Knapp v. Knapp (1986), 24 Ohio St.”
Gilbraith v. Hixson, 512 N.E.2d 956 (Ohio 1987). “e to the extent that it reaches judicial action, the provision is limited explicitly to orders requiring only the payment of child support; it does not bring within its sweep those markedly different instances in which a determination of paternity is made as part of the…”
Bourque v. Bourque, 518 N.E.2d 49 (Ohio Ct. App. 1986). “Unlike a separation agreement made pursuant to a dissolution under R.C. 3105.61, a trial court in a divorce action has discretionary authority to modify the parties’ agreement.”
Vrabel v. Vrabel, 459 N.E.2d 1298 (Ohio Ct. App. 1983). “01; consent dissolu-tions, R.C. 3105.61 et seq.; alimony and property division, R.”
Carey v. Carey, 459 N.E.2d 626 (Ohio Ct. App. 1983). “Such determination based on the evidentiary matters before the trial court on plaintiffs motion for summary judgment would necessitate a weighing of facts which cannot be accomplished in a summary judgment action.”
Linehan v. Linehan, 517 N.E.2d 967 (Ohio Ct. App. 1986). · cites it 2× “I and II The appellant’s (wife’s) first and second assignments of error are: I “The trial court erred, to the prejudice of appellant, in modifying alimony and property settlement provisions of the separation agreement incorporated in a decree of dissolution as provided in…”
Hill v. Hill, 2017 Ohio 2625 (Ohio Ct. App. 2017). · cites it 2× “R.C. §§ 3105.61 et seq., 3105.63. R.C. 3105.”
Morgan v. Morgan, 711 N.E.2d 1059 (Ohio Ct. App. 1998). · cites it 2× “Mutual consent to the separation agreement was one of the two essential elements required for a valid judgment of dissolution. After vacating judgment on the original separation agreement due to incomplete disclosure, the court was obligated to dismiss the petition for…”
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