Notes of Decisions
Cited in
76
cases (
18 in the last 5 years), 2005–2026 · leading case:
Siferd v. Siferd, 2017 Ohio 8624 (Ohio Ct. App. 2017).
Siferd v. Siferd, 2017 Ohio 8624 (Ohio Ct. App. 2017).
· cites it 7× “For this reason, Ronald contends that the trial court erred by failing to comply with the requirements of R.C. 3119.24 and should, therefore, be reversed.”
Mahlerwein v. Mahlerwein, 828 N.E.2d 153 (Ohio Ct. App. 2005).
· cites it 5× “” However, in the context of a shared-parenting order, R.C. 3119.24 authorizes the court to deviate from the guideline calculation if that amount “would be unjust or inappropriate to the children or either parent and would not be in the best interest of the child because of…”
Irish v. Irish, 2011 Ohio 3111 (Ohio Ct. App. 2011).
· cites it 9× “23 and each of 4 the four extraordinary circumstances set forth in R.C. 3119.24. After it determined that some of those factors were “potentially relevant” based on the evidence presented at the hearing, and after it analyzed those factors and circumstances, the court determined…”
In re K.R.B., 2017 Ohio 7071 (Ohio Ct. App. 2017).
· cites it 6× “{¶ 14} R.C. 3119.24 applies in cases involving shared parenting.”
Mangen v. Mangen, 2021 Ohio 3693 (Ohio Ct. App. 2021).
· cites it 7× “Child Support Calculation Under R.C. 3119.24 {¶ 5} Douglas’s first assignment of error states: THE TRIAL COURT [ERRED] AS A MATTER OF LAW AND AS A MATTER OF FACT IN THE MANNER AND METHOD IT CALCULATED FATHER’S CHILD SUPPORT OBLIGATION.”
Caleshu v. Caleshu, 2020 Ohio 4075 (Ohio Ct. App. 2020).
· cites it 4× “As to matters involving shared parenting, R.C. 3119.24 permits a trial court to deviate from the guideline calculation if that amount "would be unjust or inappropriate to the children or either parent and therefore not in the best interest of the child because of the…”
Hurte v. Hurte, 842 N.E.2d 1058 (Ohio Ct. App. 2005).
· cites it 3× “24(A)(1) allows a court to deviate from the rebuttably presumed amount “if that amount would be unjust or inappropriate to the children or either parent and would not be in the best interest of the child because of the extraordinary circumstances of the parents or because of any…”
Siferd v. Siferd, 2018 Ohio 3616 (Ohio Ct. App. 2018).
· cites it 6× “Legal Standard {¶31} R.C. 3119.24, which governs the award of child support when the trial court issues a shared parenting order, reads, in its relevant part, as follows: A court that issues a shared parenting order in accordance with section 3109.”
Mattis v. Mattis, 2016 Ohio 1084 (Ohio Ct. App. 2016).
· cites it 4× “) Thus, Father is not entitled to an automatic credit or reduction in the child support, however, the time the children spend with him was an extraordinary factor that the trial court considered.”
Getreu v. Getreu, 2021 Ohio 2761 (Ohio Ct. App. 2021).
· cites it 5× “R.C. 3119.24; Glover v. Canann, 11th Dist.”
Borer v. Borer, 2009 Ohio 6522 (Ohio Ct. App. 2009).
· cites it 12× “13-06-38, 2007-Ohio- 3341, this Court affirmed in part, and reversed in part, the judgment of the trial court, finding that, although the magistrate “found that the imposition of the child support amount calculated pursuant to the child support schedule would be unjust,…”
Hackett v. Hackett, 2013 Ohio 4684 (Ohio Ct. App. 2013).
· cites it 12× “THE TRIAL COURT ERRED, AS A MATTER OF LAW, BY FAILING TO APPLY R.C. §3119.24 IN ITS ANALYSIS OF THE DEVIATION OF CHILD SUPPORT.”
— Ohio Rev. Code § 3119.24(2) — 1 case
— Ohio Rev. Code § 3119.24(2)(B) — 1 case
— Ohio Rev. Code § 3119.24(A) — 15 cases
Mattis v. Mattis, 2016 Ohio 1084 (Ohio Ct. App. 2016).
“) Thus, Father is not entitled to an automatic credit or reduction in the child support, however, the time the children spend with him was an extraordinary factor that the trial court considered.”
In re K.R.B., 2017 Ohio 7071 (Ohio Ct. App. 2017).
“{¶ 14} R.C. 3119.24 applies in cases involving shared parenting.”
— Ohio Rev. Code § 3119.24(A)(1) — 21 cases
Siferd v. Siferd, 2017 Ohio 8624 (Ohio Ct. App. 2017).
“For this reason, Ronald contends that the trial court erred by failing to comply with the requirements of R.C. 3119.24 and should, therefore, be reversed.”
Hurte v. Hurte, 842 N.E.2d 1058 (Ohio Ct. App. 2005).
“24(A)(1) allows a court to deviate from the rebuttably presumed amount “if that amount would be unjust or inappropriate to the children or either parent and would not be in the best interest of the child because of the extraordinary circumstances of the parents or because of any…”
Irish v. Irish, 2011 Ohio 3111 (Ohio Ct. App. 2011).
“23 and each of 4 the four extraordinary circumstances set forth in R.C. 3119.24. After it determined that some of those factors were “potentially relevant” based on the evidence presented at the hearing, and after it analyzed those factors and circumstances, the court determined…”
— Ohio Rev. Code § 3119.24(A)(2) — 16 cases
Siferd v. Siferd, 2017 Ohio 8624 (Ohio Ct. App. 2017).
“For this reason, Ronald contends that the trial court erred by failing to comply with the requirements of R.C. 3119.24 and should, therefore, be reversed.”
Mahlerwein v. Mahlerwein, 828 N.E.2d 153 (Ohio Ct. App. 2005).
“” However, in the context of a shared-parenting order, R.C. 3119.24 authorizes the court to deviate from the guideline calculation if that amount “would be unjust or inappropriate to the children or either parent and would not be in the best interest of the child because of…”
Hurte v. Hurte, 842 N.E.2d 1058 (Ohio Ct. App. 2005).
“24(A)(1) allows a court to deviate from the rebuttably presumed amount “if that amount would be unjust or inappropriate to the children or either parent and would not be in the best interest of the child because of the extraordinary circumstances of the parents or because of any…”
Siferd v. Siferd, 2018 Ohio 3616 (Ohio Ct. App. 2018).
“Legal Standard {¶31} R.C. 3119.24, which governs the award of child support when the trial court issues a shared parenting order, reads, in its relevant part, as follows: A court that issues a shared parenting order in accordance with section 3109.”
— Ohio Rev. Code § 3119.24(B) — 20 cases
Mahlerwein v. Mahlerwein, 828 N.E.2d 153 (Ohio Ct. App. 2005).
“” However, in the context of a shared-parenting order, R.C. 3119.24 authorizes the court to deviate from the guideline calculation if that amount “would be unjust or inappropriate to the children or either parent and would not be in the best interest of the child because of…”
In re K.R.B., 2017 Ohio 7071 (Ohio Ct. App. 2017).
“{¶ 14} R.C. 3119.24 applies in cases involving shared parenting.”
Siferd v. Siferd, 2017 Ohio 8624 (Ohio Ct. App. 2017).
“For this reason, Ronald contends that the trial court erred by failing to comply with the requirements of R.C. 3119.24 and should, therefore, be reversed.”
Caleshu v. Caleshu, 2020 Ohio 4075 (Ohio Ct. App. 2020).
“As to matters involving shared parenting, R.C. 3119.24 permits a trial court to deviate from the guideline calculation if that amount "would be unjust or inappropriate to the children or either parent and therefore not in the best interest of the child because of the…”
— Ohio Rev. Code § 3119.24(B)(1) — 6 cases
Hurte v. Hurte, 842 N.E.2d 1058 (Ohio Ct. App. 2005).
“24(A)(1) allows a court to deviate from the rebuttably presumed amount “if that amount would be unjust or inappropriate to the children or either parent and would not be in the best interest of the child because of the extraordinary circumstances of the parents or because of any…”
Caleshu v. Caleshu, 2020 Ohio 4075 (Ohio Ct. App. 2020).
“As to matters involving shared parenting, R.C. 3119.24 permits a trial court to deviate from the guideline calculation if that amount "would be unjust or inappropriate to the children or either parent and therefore not in the best interest of the child because of the…”
— Ohio Rev. Code § 3119.24(B)(3) — 4 cases
Irish v. Irish, 2011 Ohio 3111 (Ohio Ct. App. 2011).
“23 and each of 4 the four extraordinary circumstances set forth in R.C. 3119.24. After it determined that some of those factors were “potentially relevant” based on the evidence presented at the hearing, and after it analyzed those factors and circumstances, the court determined…”
— Ohio Rev. Code § 3119.24(B)(4) — 1 case
Borer v. Borer, 2009 Ohio 6522 (Ohio Ct. App. 2009).
“13-06-38, 2007-Ohio- 3341, this Court affirmed in part, and reversed in part, the judgment of the trial court, finding that, although the magistrate “found that the imposition of the child support amount calculated pursuant to the child support schedule would be unjust,…”
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