Ohio Rev. Code » Chapter 3119 - Ohio Revised Code | Ohio Laws
Ohio Revised Code

Ohio Rev. Code § 3119.79 (2026)

Modification of child support

✓ current as of May 2026
Find cases: SyfertCases citing this section ORCcodes.ohio.gov (official) Justiaon Justia CornellLII Search CasesGoogle Scholar
Effective:
March 28, 2019
Latest Legislation:
House Bill 366 - 132nd General Assembly
PDF:
Download Authenticated PDF
 

(A) If an obligor or obligee under a child support order requests that the court modify the amount of child support required to be paid pursuant to the child support order, the court shall recalculate the amount of support that would be required to be paid under the child support order in accordance with the schedule and the applicable worksheet . If that amount as recalculated is more than ten per cent greater than or more than ten per cent less than the amount of child support required to be paid pursuant to the existing child support order, the deviation from the recalculated amount that would be required to be paid under the schedule and the applicable worksheet shall be considered by the court as a change of circumstance substantial enough to require a modification of the child support amount.

(B) If the court determines that the medical needs of the child are not being met because of inadequate health insurance coverage, the inadequate coverage shall be considered by the court as a change of circumstance that is substantial enough to require a modification of the child support order.

(C) If the court determines that the amount of child support required to be paid under the child support order should be changed due to a substantial change of circumstances that was not contemplated at the time of the issuance of the original child support order or the last modification of the child support order, the court shall modify the amount of child support required to be paid under the child support order to comply with the schedule and the applicable worksheet , unless the court determines that those amounts calculated pursuant to the basic child support schedule and pursuant to the applicable worksheet would be unjust or inappropriate and therefore not in the best interest of the child and enters in the journal the figure, determination, and findings specified in section 3119.22 of the Revised Code.

Last updated February 2, 2026 at 11:31 AM

Notes of Decisions
Cited in 133 cases (33 in the last 5 years), 2005–2026 · leading case: Mossing-Landers v. Landers, 2016 Ohio 7625 (Ohio Ct. App. 2016).
Sort: Relevance Newest Treatment
Mossing-Landers v. Landers, 2016 Ohio 7625 (Ohio Ct. App. 2016). · cites it 23× “Parties are entitled to file for modification at any time under R.C. 3119.79, assuming they can prove a change in circumstances under that section, and assuming they did not agree to forego attempts to modify support.”
Phelps v. Saffian, 2016 Ohio 5514 (Ohio Ct. App. 2016). · cites it 9× “{¶13} When the parties to a child support order collectively earn more than $150,000, what constitutes a substantial change of circumstances from the original support order is unclear.”
Funkhouser v. Funkhouser, 2019 Ohio 733 (Ohio Ct. App. 2019). · cites it 10× “{¶ 35} Appellant’s request for the trial court to modify the existing child support order was governed by R.C. 3119.79. Carver v. Carver, 6th Dist.”
Haun v. Haun, 2019 Ohio 5408 (Ohio Ct. App. 2019). · cites it 10× “{¶9} R.C. 3119.79 governs motions to modify child support.”
Adams v. Adams, 2012 Ohio 5131 (Ohio Ct. App. 2012). · cites it 13× “{¶20} R.C. 3119.79 sets forth the necessary criteria and methodology for a trial court to modify an existing child support order as follows: (A) If an obligor or obligee under a child support order requests that the court modify the amount of support required to be paid pursuant…”
Abbey v. Peavy, 2014 Ohio 3921 (Ohio Ct. App. 2014). · cites it 11× “” {¶17} Abbey argues that the Bonner court and, thus, the magistrate in this case, interpreted R.C. 3119.79 incorrectly. Abbey maintains that under R.”
Hock v. Soles, 2022 Ohio 3531 (Ohio Ct. App. 2022). · cites it 20× “CHILD SUPPORT MODIFICATION STATUTE {¶19} The parties contest the relationship between division (A) and (C) of R.C. 3119.79. The statute contains the following three sections: (A) If an obligor or obligee under a child support order requests that the court modify the amount of…”
Abrams v. Abrams, 2017 Ohio 4319 (Ohio Ct. App. 2017). · cites it 5× “{¶ 40} " 'In order to modify child support, the trial court must find a substantial change in circumstances, which is defined in R.C. 3119.79(A) as a ten-percent deviation from the amount of child support previously ordered.”
Sapinsley v. Sapinsley, 869 N.E.2d 702 (Ohio Ct. App. 2007). · cites it 7× “We held that the trial court erred by failing to “strictly comply with the terms of R.C. 3119.79 by completing a child-support worksheet and including it in the record.”
Adams v. Adams, 2013 Ohio 2947 (Ohio Ct. App. 2013). · cites it 10× “79 controls the modification of child support orders and provides, in pertinent part, as follows: (A) If an obligor or obligee under a child support order requests that the court modify the amount of support required to be paid pursuant to the child support order, the court…”
Mahlerwein v. Mahlerwein, 828 N.E.2d 153 (Ohio Ct. App. 2005). · cites it 3× “{¶ 33} R.C. 3119.79(A) provides: “If an obligor or obligee under a child support order requests that the court modify the amount of support required to be paid pursuant to the child support order, the court shall recalculate the amount of *576 support that would be required to…”
Trombley v. Trombley, 2018 Ohio 1880 (Ohio Ct. App. 2018). · cites it 4× “Pursuant to R.C. 3119.79, a prior child support obligation may not be modified absent a showing of a substantial change in circumstances.”
Show all 133 citing cases →
— Ohio Rev. Code § 3119.79(A) — 95 cases
Mossing-Landers v. Landers, 2016 Ohio 7625 (Ohio Ct. App. 2016). “Parties are entitled to file for modification at any time under R.C. 3119.79, assuming they can prove a change in circumstances under that section, and assuming they did not agree to forego attempts to modify support.”
Abrams v. Abrams, 2017 Ohio 4319 (Ohio Ct. App. 2017). “{¶ 40} " 'In order to modify child support, the trial court must find a substantial change in circumstances, which is defined in R.C. 3119.79(A) as a ten-percent deviation from the amount of child support previously ordered.”
Funkhouser v. Funkhouser, 2019 Ohio 733 (Ohio Ct. App. 2019). “{¶ 35} Appellant’s request for the trial court to modify the existing child support order was governed by R.C. 3119.79. Carver v. Carver, 6th Dist.”
Sapinsley v. Sapinsley, 869 N.E.2d 702 (Ohio Ct. App. 2007). “We held that the trial court erred by failing to “strictly comply with the terms of R.C. 3119.79 by completing a child-support worksheet and including it in the record.”
Mahlerwein v. Mahlerwein, 828 N.E.2d 153 (Ohio Ct. App. 2005). “{¶ 33} R.C. 3119.79(A) provides: “If an obligor or obligee under a child support order requests that the court modify the amount of support required to be paid pursuant to the child support order, the court shall recalculate the amount of *576 support that would be required to…”
— Ohio Rev. Code § 3119.79(B) — 3 cases
Mossing-Landers v. Landers, 2016 Ohio 7625 (Ohio Ct. App. 2016). “Parties are entitled to file for modification at any time under R.C. 3119.79, assuming they can prove a change in circumstances under that section, and assuming they did not agree to forego attempts to modify support.”
Behning v. Behning, 2019 Ohio 1429 (Ohio Ct. App. 2019).
Lloyd v. Lloyd, 2024 Ohio 56 (Ohio Ct. App. 2024).
— Ohio Rev. Code § 3119.79(C) — 47 cases
Phelps v. Saffian, 2016 Ohio 5514 (Ohio Ct. App. 2016). “{¶13} When the parties to a child support order collectively earn more than $150,000, what constitutes a substantial change of circumstances from the original support order is unclear.”
Haun v. Haun, 2019 Ohio 5408 (Ohio Ct. App. 2019). “{¶9} R.C. 3119.79 governs motions to modify child support.”
Adams v. Adams, 2013 Ohio 2947 (Ohio Ct. App. 2013). “79 controls the modification of child support orders and provides, in pertinent part, as follows: (A) If an obligor or obligee under a child support order requests that the court modify the amount of support required to be paid pursuant to the child support order, the court…”
Adams v. Adams, 2012 Ohio 5131 (Ohio Ct. App. 2012). “{¶20} R.C. 3119.79 sets forth the necessary criteria and methodology for a trial court to modify an existing child support order as follows: (A) If an obligor or obligee under a child support order requests that the court modify the amount of support required to be paid pursuant…”
Mattis v. Mattis, 2016 Ohio 1084 (Ohio Ct. App. 2016).
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.