Ohio Revised Code

Ohio Rev. Code § 3105.89 (2026)

Court retains jurisdiction - modification of orders

✓ laws through the 2026 session (checked Sept. 2026)
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Notwithstanding division (I) of section 3105.171 of the Revised Code:

(A) The court shall retain jurisdiction to modify, supervise, or enforce the implementation of an order described in section 3105.81 of the Revised Code.

(B) The court may modify an order issued under section 3105.171 or 3105.65 of the Revised Code that was effective prior to the effective date of this section for the purpose of enforcing the order or carrying into effect the manifest intentions of the parties. A modified order must meet the requirements of section 3105.82 of the Revised Code.

Notes of Decisions
Cited in 10 cases (1 in the last 5 years), 2001–2022 · leading case: Ouellette v. Ouellette, 2020-Ohio-705, 152 N.E.3d 528.
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Ouellette v. Ouellette, 2020-Ohio-705, 152 N.E.3d 528. · cites it 8× “While acknowledging the lack of consent, appellee argues that R.C. 3105.89 provides an exception to the consent requirement under R.”
Williams v. Williams, 2022-Ohio-599. · cites it 19× “R.C. 3105.89 {¶19} Patricia argues that the trial court was statutorily permitted to modify the divorce decree, notwithstanding R.”
Enty v. Enty, 2017-Ohio-4177. · cites it 3× “In our review, “R.C. 3105.89 does afford a trial court some continuing jurisdiction over division of property orders involving public retirement programs.”
Erb v. Erb, 747 N.E.2d 230 (Ohio 2001). “R.C. 3105.89(B). The fund urges this court to hold that the passage of H.”
Hines v. Hines, 2010-Ohio-4807. · cites it 2× “) {¶10} On appeal, Paul argues the trial court erroneously concluded that it did not have jurisdiction to modify the property division.”
Fiedler v. Fiedler, 2016-Ohio-5349. · cites it 2× “171(I), which provides that “[a] division or disbursement of property or a distributive award * * * is not subject to future modification by the court except upon the express written consent or agreement to the modification by both spouses.” Cynthia nevertheless recognizes that…”
Patterson v. Patterson, 784 N.E.2d 1213 (Ohio Ct. App. 12th Dist. 2003). · cites it 2× “” R.C. 3105.89 requires the modified order to meet the requirements set forth in R.”
Murphy-Kesling v. Kesling, 2014-Ohio-1816. · cites it 4× “{¶9} Revised Code Section 3105.89(A) provides that the court that issues a division of property order “shall retain jurisdiction to modify, supervise, or enforce the implementation of [the] order * * *.”
Erb v. Erb, 91 Ohio St. 3d 503 (2001). “R.C. 3105.89(B). {¶ 23} The fund urges this court to hold that the passage of H.”
Binkley v. Coleman, 2010-Ohio-4824. “However, the Domestic Relations Court retains the power to enforce the provisions of a divorce decree or to modify an order to carry into effect the manifest intentions of the parties.”
Ohio Rev. Code § 3105.89(A): 3 cases
Ouellette v. Ouellette, 2020-Ohio-705, 152 N.E.3d 528. “While acknowledging the lack of consent, appellee argues that R.C. 3105.89 provides an exception to the consent requirement under R.”
Williams v. Williams, 2022-Ohio-599. “R.C. 3105.89 {¶19} Patricia argues that the trial court was statutorily permitted to modify the divorce decree, notwithstanding R.”
Murphy-Kesling v. Kesling, 2014-Ohio-1816. “{¶9} Revised Code Section 3105.89(A) provides that the court that issues a division of property order “shall retain jurisdiction to modify, supervise, or enforce the implementation of [the] order * * *.”
Ohio Rev. Code § 3105.89(B): 4 cases
Erb v. Erb, 747 N.E.2d 230 (Ohio 2001). “R.C. 3105.89(B). The fund urges this court to hold that the passage of H.”
Williams v. Williams, 2022-Ohio-599. “R.C. 3105.89 {¶19} Patricia argues that the trial court was statutorily permitted to modify the divorce decree, notwithstanding R.”
Patterson v. Patterson, 784 N.E.2d 1213 (Ohio Ct. App. 12th Dist. 2003). “” R.C. 3105.89 requires the modified order to meet the requirements set forth in R.”
Erb v. Erb, 91 Ohio St. 3d 503 (2001). “R.C. 3105.89(B). {¶ 23} The fund urges this court to hold that the passage of H.”
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