(A) If court-ordered parenting time exceeds ninety overnights per year, the court shall consider whether to grant a deviation pursuant to section 3119.22 of the Revised Code for the reason set forth in division (C) of section 3119.23 of the Revised Code. 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 (A) of this section, it shall specify in the order the facts that are the basis for the court's decision.
Notes of Decisions
Cited in 24
cases (22 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 23ד051 and R.C. 3119.231 {¶ 19} The second assignment of error raised by Douglas states: THE TRIAL COURT ERRED BY FAILING TO ISSUE FINDINGS OF FACT AND CONCLUSIONS OF LAW WHEN NOT GRANTING AN ADDITIONAL DEVIATION TO CHILD SUPPORT PURSUANT TO SECTION 3119.”
MacKnight v. MacKnight, 2022 Ohio 648 (Ohio Ct. App. 2022). · cites it 8ד{¶30} Though Father acknowledges there is no specific rule that a parent with more parenting time be named the obligee in shared parenting situations, he nonetheless contends that language in R.C. 3119.231 "implies this should be the practice.”
Caleshu v. Caleshu, 2020 Ohio 4075 (Ohio Ct. App. 2020). · cites it 5דInstead, Lee asserts that pursuant to R.C. 3119.231, the court should have resulted in a downward deviation from the guideline amount.”
Getreu v. Getreu, 2021 Ohio 2761 (Ohio Ct. App. 2021). · cites it 4ד23, R.C. 3119.231, and R.C. 3119.24, such that this Court can conduct a meaningful review as to whether the trial court abused its discretion in determining whether to deviate and in determining the deviation amount.”
Doubler v. Doubler, 2023 Ohio 393 (Ohio Ct. App. 2023). · cites it 3ד) {¶34} R.C. 3119.231 states: (A) If court-ordered parenting time exceeds ninety overnights per year, the court shall consider whether to grant a deviation pursuant to section 3119.”
In re M.C., 2021 Ohio 3703 (Ohio Ct. App. 2021). · cites it 10ד{¶ 7} According to R.C. 3119.231, which was effective before the juvenile court issued its order,1 (A) If court-ordered parenting time exceeds ninety overnights per year, the court shall consider whether to grant a deviation pursuant to section 3119.”
Combs v. Ellington, 2022 Ohio 3514 (Ohio Ct. App. 2022). · cites it 5דThough Father argued for an additional downward deviation pursuant to R.C. 3119.231 as his parenting time exceeded 147 nights per year, the magistrate denied Father's request, 2.”
Whitaker v. Whitaker, 2020 Ohio 2774 (Ohio Ct. App. 2020). · cites it 6ד{¶44} In his sixth assignment of error, Father argues the trial court erred by failing to issue findings of fact and conclusions of law after not allowing a deviation under R.C. 3119.231. We sustain Father's sixth assignment of error.”
Kitzberger v. Kitzberger, 2025 Ohio 1721 (Ohio Ct. App. 2025). · cites it 13דThe magistrate then found that a downward deviation for the full amount of support owed by mother was warranted under R.C. 3119.231. {¶5} Father objected to the magistrate’s decision, arguing that the magistrate’s decision to award the downward deviation was an abuse of…”
Bajaj v. Green, 2021 Ohio 3113 (Ohio Ct. App. 2021). “; R.C. 3119.231. {¶ 40} Pursuant to R.C. 3119.”
In re A.H., 2021 Ohio 4055 (Ohio Ct. App. 2021). · cites it 4ד] 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.”
Hock v. Soles, 2022 Ohio 3531 (Ohio Ct. App. 2022). “See R.C. 3119.231(A) (in addition to automatic reduction, the court shall consider an additional deviation for more than 90 overnights), (B) (if more than 147 overnights and court does not grant deviation, then the court shall specify the facts on which this decision is based),…”
Mangen v. Mangen, 2021 Ohio 3693 (Ohio Ct. App. 2021). “051 and R.C. 3119.231 {¶ 19} The second assignment of error raised by Douglas states: THE TRIAL COURT ERRED BY FAILING TO ISSUE FINDINGS OF FACT AND CONCLUSIONS OF LAW WHEN NOT GRANTING AN ADDITIONAL DEVIATION TO CHILD SUPPORT PURSUANT TO SECTION 3119.”
MacKnight v. MacKnight, 2022 Ohio 648 (Ohio Ct. App. 2022). “{¶30} Though Father acknowledges there is no specific rule that a parent with more parenting time be named the obligee in shared parenting situations, he nonetheless contends that language in R.C. 3119.231 "implies this should be the practice.”
Getreu v. Getreu, 2021 Ohio 2761 (Ohio Ct. App. 2021). “23, R.C. 3119.231, and R.C. 3119.24, such that this Court can conduct a meaningful review as to whether the trial court abused its discretion in determining whether to deviate and in determining the deviation amount.”
Caleshu v. Caleshu, 2020 Ohio 4075 (Ohio Ct. App. 2020). “Instead, Lee asserts that pursuant to R.C. 3119.231, the court should have resulted in a downward deviation from the guideline amount.”
Doubler v. Doubler, 2023 Ohio 393 (Ohio Ct. App. 2023). “) {¶34} R.C. 3119.231 states: (A) If court-ordered parenting time exceeds ninety overnights per year, the court shall consider whether to grant a deviation pursuant to section 3119.”
— Ohio Rev. Code § 3119.231(B) — 13 cases
Mangen v. Mangen, 2021 Ohio 3693 (Ohio Ct. App. 2021). “051 and R.C. 3119.231 {¶ 19} The second assignment of error raised by Douglas states: THE TRIAL COURT ERRED BY FAILING TO ISSUE FINDINGS OF FACT AND CONCLUSIONS OF LAW WHEN NOT GRANTING AN ADDITIONAL DEVIATION TO CHILD SUPPORT PURSUANT TO SECTION 3119.”
Caleshu v. Caleshu, 2020 Ohio 4075 (Ohio Ct. App. 2020). “Instead, Lee asserts that pursuant to R.C. 3119.231, the court should have resulted in a downward deviation from the guideline amount.”
MacKnight v. MacKnight, 2022 Ohio 648 (Ohio Ct. App. 2022). “{¶30} Though Father acknowledges there is no specific rule that a parent with more parenting time be named the obligee in shared parenting situations, he nonetheless contends that language in R.C. 3119.231 "implies this should be the practice.”
Doubler v. Doubler, 2023 Ohio 393 (Ohio Ct. App. 2023). “) {¶34} R.C. 3119.231 states: (A) If court-ordered parenting time exceeds ninety overnights per year, the court shall consider whether to grant a deviation pursuant to section 3119.”
Getreu v. Getreu, 2021 Ohio 2761 (Ohio Ct. App. 2021). “23, R.C. 3119.231, and R.C. 3119.24, such that this Court can conduct a meaningful review as to whether the trial court abused its discretion in determining whether to deviate and in determining the deviation amount.”
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