Notes of Decisions
Cited in
22
cases (
7 in the last 5 years), 2007–2025 · leading case:
France v. France, 2011 Ohio 3025 (Ohio Ct. App. 2011).
France v. France, 2011 Ohio 3025 (Ohio Ct. App. 2011).
· cites it 19× “07(A), the trial court was required to presume that the Father’s child-support obligation was spent on his children as part of his daily spending, and thus, the court did not have the authority in this case to order the Father to pay child support to the Mother.”
Hattenbach v. Watson, 2016 Ohio 5648 (Ohio Ct. App. 2016).
· cites it 5× “” {¶ 9} Watson attempts to distinguish Pauly, claiming that R.C. 3119.07 is applicable to this case, by arguing that the context of the Shared Parenting Plan clearly demonstrates that the parties intended to make one parent a non-residential, non- custodial parent during the…”
Hensley v. Hensley, 2024 Ohio 5751 (Ohio Ct. App. 2024).
· cites it 9× “Father asserts that as the sole residential parent and legal custodian of the children, he should have been designated the child support obligee pursuant to R.C. 3119.07(A) and not required to pay child support to Mother.”
Pelger v. Pelger, 2019 Ohio 1280 (Ohio Ct. App. 2019).
· cites it 2× “1 “[T]he child support computation 1 This Fifth District case noted that R.C. 3119.07(C)(7) defines “gross income” as including spousal support “actually received.”
In re A.D., 2023 Ohio 2442 (Ohio Ct. App. 2023).
“231; R.C. 3119.07(C). Thus, this portion of their argument lacks merit.”
Funkhouser v. Funkhouser, 2019 Ohio 733 (Ohio Ct. App. 2019).
“See R.C. 3119.07(B). The basic child support schedule is stated in R.”
Ash v. Dean, 2016 Ohio 5589 (Ohio Ct. App. 2016).
· cites it 2× “07(A): [e]xcept when the parents have split parental rights and responsibilities, a parent's child support obligation for a child for whom the parent is the residential parent and legal custodian shall be presumed to be spent on that child and shall not become part of a child…”
MacKnight v. MacKnight, 2022 Ohio 648 (Ohio Ct. App. 2022).
“" In situations where one parent is the sole residential parent, R.C. 3119.07(A) provides that the nonresidential parent shall be named the child support obligor.”
Mayberry v. Mayberry, 2016 Ohio 1031 (Ohio Ct. App. 2016).
“" R.C. 3119.07(C)(7)(e). A "[n]onrecurring or unsustainable income or cash flow item" is: [a]n income or cash flow item the parent receives in any year or for any number of years not to exceed three years that the parent does not expect to continue to receive on a regular basis.”
Lindman v. Geissler, 872 N.E.2d 356 (Ohio Ct. App. 2007).
“Appellant appealed to this court, asserting: “The trial court erred when it failed to designate [appellee] as the obligor and [appellant] as the obligee on the child support worksheet.”
Gamble v. Gamble, 2025 Ohio 2381 (Ohio Ct. App. 2025).
· cites it 13× “) (noting that, "[i]n situations where one parent is the sole residential parent, R.C. 3119.07[A] provides that the nonresidential parent shall be named the child support obligor").”
Saylers v. Salyers, 2025 Ohio 1605 (Ohio Ct. App. 2025).
“More importantly, pursuant to R.C. 3119.07, “the parent who has been designated the residential parent shall not be ordered to pay the child support figure that appears in his or her column on line 24 of the worksheet provided in the Revised Code.”
— Ohio Rev. Code § 3119.07(A) — 9 cases
France v. France, 2011 Ohio 3025 (Ohio Ct. App. 2011).
“07(A), the trial court was required to presume that the Father’s child-support obligation was spent on his children as part of his daily spending, and thus, the court did not have the authority in this case to order the Father to pay child support to the Mother.”
Hattenbach v. Watson, 2016 Ohio 5648 (Ohio Ct. App. 2016).
“” {¶ 9} Watson attempts to distinguish Pauly, claiming that R.C. 3119.07 is applicable to this case, by arguing that the context of the Shared Parenting Plan clearly demonstrates that the parties intended to make one parent a non-residential, non- custodial parent during the…”
Hensley v. Hensley, 2024 Ohio 5751 (Ohio Ct. App. 2024).
“Father asserts that as the sole residential parent and legal custodian of the children, he should have been designated the child support obligee pursuant to R.C. 3119.07(A) and not required to pay child support to Mother.”
Ash v. Dean, 2016 Ohio 5589 (Ohio Ct. App. 2016).
“07(A): [e]xcept when the parents have split parental rights and responsibilities, a parent's child support obligation for a child for whom the parent is the residential parent and legal custodian shall be presumed to be spent on that child and shall not become part of a child…”
MacKnight v. MacKnight, 2022 Ohio 648 (Ohio Ct. App. 2022).
“" In situations where one parent is the sole residential parent, R.C. 3119.07(A) provides that the nonresidential parent shall be named the child support obligor.”
— Ohio Rev. Code § 3119.07(B) — 2 cases
Funkhouser v. Funkhouser, 2019 Ohio 733 (Ohio Ct. App. 2019).
“See R.C. 3119.07(B). The basic child support schedule is stated in R.”
— Ohio Rev. Code § 3119.07(C) — 4 cases
In re A.D., 2023 Ohio 2442 (Ohio Ct. App. 2023).
“231; R.C. 3119.07(C). Thus, this portion of their argument lacks merit.”
— Ohio Rev. Code § 3119.07(C)(13) — 1 case
— Ohio Rev. Code § 3119.07(C)(17) — 1 case
— Ohio Rev. Code § 3119.07(C)(7) — 1 case
Pelger v. Pelger, 2019 Ohio 1280 (Ohio Ct. App. 2019).
“1 “[T]he child support computation 1 This Fifth District case noted that R.C. 3119.07(C)(7) defines “gross income” as including spousal support “actually received.”
— Ohio Rev. Code § 3119.07(C)(7)(e) — 1 case
Mayberry v. Mayberry, 2016 Ohio 1031 (Ohio Ct. App. 2016).
“" R.C. 3119.07(C)(7)(e). A "[n]onrecurring or unsustainable income or cash flow item" is: [a]n income or cash flow item the parent receives in any year or for any number of years not to exceed three years that the parent does not expect to continue to receive on a regular basis.”
— Ohio Rev. Code § 3119.07(C)(9) — 1 case
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