(A) Except as otherwise provided in this section, a court or child support enforcement agency calculating the amount to be paid under a child support order shall reduce by ten per cent the amount of the annual individual support obligation for the parent or parents when a court has issued or is issuing a court-ordered parenting time order that equals or exceeds ninety overnights per year. This reduction may be in addition to the other deviations and reductions.
(B) At the request of the obligee, a court may eliminate a previously granted adjustment established under division (A) of this section if the obligor, without just cause, has failed to exercise court-ordered parenting time.
Notes of Decisions
Cited in 31
cases (29 in the last 5 years), 2020–2026 · leading case: Mangen v. Mangen, 2021 Ohio 3693 (Ohio Ct. App. 2021).
Mangen v. Mangen, 2021 Ohio 3693 (Ohio Ct. App. 2021). · cites it 17ד{¶ 16} The record demonstrates the trial court granted a 10% downward deviation to Douglas under the authority of either R.C. 3119.051 or R.C. 3119.231(A).3 However, after considering the R.”
Caleshu v. Caleshu, 2020 Ohio 4075 (Ohio Ct. App. 2020). · cites it 4ד231(A), the trial court may grant an additional deviation along with the deviation contained in R.C. 3119.051. Moreover, if the overnight parenting time exceeds the overnights contained in R.”
Getreu v. Getreu, 2021 Ohio 2761 (Ohio Ct. App. 2021). · cites it 6דIf the obligor enjoys more than 147 overnights per year, as Father does here, the guidelines provide that the court will consider a deviation in addition to the R.C. 3119.051 deviation. R.C. 3119.231(B).”
Doubler v. Doubler, 2023 Ohio 393 (Ohio Ct. App. 2023). · cites it 5דThis deviation is in addition to any adjustments provided under division (A) of section 3119.051 of the Revised Code. (B) If court-ordered parenting time is equal to or exceeds one hundred forty-seven overnights per year, and the court does not grant a deviation under division…”
MacKnight v. MacKnight, 2022 Ohio 648 (Ohio Ct. App. 2022). · cites it 3ד{¶19} With respect to Father's child support obligation, the court found that Father was entitled to a 10 percent downward deviation for extended parenting time under R.C. 3119.051, as Father's parenting time exceeded 90 overnights.”
Reid v. Reid, 2023 Ohio 3140 (Ohio Ct. App. 2023). · cites it 4ד{¶ 14} In his third assignment of error, husband claims that the trial court erred in failing to determine “if” he had 90 or more nights with his children, which would have entitled him to a ten percent reduction in child support, under R.”
Combs v. Ellington, 2022 Ohio 3514 (Ohio Ct. App. 2022). · cites it 6דHowever, the magistrate determined that Father was entitled to a 10 percent downward deviation from the guideline support for extended parenting time under R.C. 3119.051(A), as Father's parenting time exceeded 90 overnights.”
In re M.C., 2021 Ohio 3703 (Ohio Ct. App. 2021). · cites it 8דR.C. 3119.051. Then, and if a parent's court-ordered parenting time exceeds 90 overnights per year, the trial court shall consider whether a deviation in addition to that provided by R.”
Whitaker v. Whitaker, 2020 Ohio 2774 (Ohio Ct. App. 2020). · cites it 4ד{¶45} In the present case, the trial court ordered a ten percent deviation as Father's parenting time exceeded 90 days as provided in R.C. 3119.051. However, on March 28, 2019, shortly before the final judgment entry, R.”
In re A.H., 2021 Ohio 4055 (Ohio Ct. App. 2021). · cites it 5ד] Alternatively, the trial court erred by not complying with the new child support statutes in ordering the amount of child support recommended by the Geauga County Child Support Enforcement Division and not granting the deviation for parenting time required by R.”
Glover v. Canann, 2021 Ohio 2641 (Ohio Ct. App. 2021). · cites it 3דR.C. 3119.051. If the obligor enjoys more than 147 overnights per year, as Father does here, the guidelines provide that the court will consider a deviation in addition to the R.”
Bajaj v. Green, 2021 Ohio 3113 (Ohio Ct. App. 2021). “R.C. 3119.051. This 10-percent reduction may be in addition to the other deviations and reductions.”
Doubler v. Doubler, 2023 Ohio 393 (Ohio Ct. App. 2023). “This deviation is in addition to any adjustments provided under division (A) of section 3119.051 of the Revised Code. (B) If court-ordered parenting time is equal to or exceeds one hundred forty-seven overnights per year, and the court does not grant a deviation under division…”
Caleshu v. Caleshu, 2020 Ohio 4075 (Ohio Ct. App. 2020). “231(A), the trial court may grant an additional deviation along with the deviation contained in R.C. 3119.051. Moreover, if the overnight parenting time exceeds the overnights contained in R.”
Combs v. Ellington, 2022 Ohio 3514 (Ohio Ct. App. 2022). “However, the magistrate determined that Father was entitled to a 10 percent downward deviation from the guideline support for extended parenting time under R.C. 3119.051(A), as Father's parenting time exceeded 90 overnights.”
MacKnight v. MacKnight, 2022 Ohio 648 (Ohio Ct. App. 2022). “{¶19} With respect to Father's child support obligation, the court found that Father was entitled to a 10 percent downward deviation for extended parenting time under R.C. 3119.051, as Father's parenting time exceeded 90 overnights.”
Getreu v. Getreu, 2021 Ohio 2761 (Ohio Ct. App. 2021). “If the obligor enjoys more than 147 overnights per year, as Father does here, the guidelines provide that the court will consider a deviation in addition to the R.C. 3119.051 deviation. R.C. 3119.231(B).”
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