Ohio Revised Code

Ohio Rev. Code § 3119.84 (2026)

Modifying payments accruing while modification proceedings are pending

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A court with jurisdiction over a court support order may modify an obligor's duty to pay a support payment that becomes due after notice of a petition to modify the court support order has been given to each obligee and to the obligor before a final order concerning the petition for modification is entered.

Notes of Decisions
Cited in 21 cases (6 in the last 5 years), 2003–2025 · leading case: In re J.S., 2012-Ohio-421.
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In re J.S., 2012-Ohio-421. · cites it 7× “” R.C. 3119.84 provides: “A court with jurisdiction over a court support order may modify an obligor’s duty to pay a support payment that becomes due after notice of a petition to modify the court support order has been given to each obligee and to the obligor before a final…”
Byrd v. Knuckles, 900 N.E.2d 164 (Ohio 2008). · cites it 3× “{¶ 4} R.C. 3119.84, the exception to R.C. 3119.”
Walker v. Walker, 784 N.E.2d 127 (Ohio Ct. App. 7th Dist. 2003). · cites it 4× “” {¶ 19} R.C. 3119.84 states: {¶ 20} “A court with jurisdiction over a court support order may modify an obligor’s duty to pay a support payment that becomes due after notice of a petition to modify the court support order has been given to each obligee and to the obligor before…”
Behnken v. Behnken, 2020-Ohio-389. · cites it 4× “83 and R.C. 3119.84. Entry Overruling Objections (May 30, 2019), p.”
Phelps v. Saffian, 2016-Ohio-5514. “The magistrate ordered support modification retroactive to the date when Phelps filed her motion to modify child support.”
Ward v. Ward, 2016-Ohio-5178. “Appellee's October 8, 2013 motion to modify child support was predicated on a change of circumstances.”
In re S.C., 2020-Ohio-233, 151 N.E.3d 953. “CA2008-02- 014, 2008-Ohio-5668, ¶ 21 ; R.C. 3119.84. Ohio courts have held that an exception to that rule is that a trial court may modify the support obligation to a time before the motion was filed if the court finds that the support obligor perpetuated fraud.”
In re K.A.V., 2014-Ohio-5575. “In the same vein, R.C. 3119.84 provides that “[a] court with jurisdiction over a court support order may modify an obligor’s duty to pay a support payment that becomes due after notice of a petition to modify the court support order has been 3 The general rule is that a…”
Cauthen v. Cauthen, 2017-Ohio-5846. “Further, she argues that R.C. 3119.84 says that a court may modify a child support arrearage only to the extent that the arrearage accrues after a petition to modify the order has been given to each obligee and to the obligor before a final order concerning the petition…”
Crandall v. Crandall, 2020-Ohio-625. “5 {¶22} R.C. 3119.84 allows the court to “modify an obligor’s duty to pay a support payment that becomes due after notice of a petition to modify the court support order has been given to each obligee and to the obligor before a final order concerning the petition for…”
Winn v. Wilson, 2018-Ohio-1010. “{¶ 39} R.C. 3119.84 provides that a court "may modify an obligor's duty to pay a support payment that becomes due after notice of a petition to modify the court support order has been given to each obligee and to the obligor before a final order concerning the petition -9-…”
Fenicle v. Heinze, 2024-Ohio-2941, 249 N.E.3d 360. · cites it 5× “R.C. 3119.84. IV. The trial court erred when it made Mother the child support obligor under a shared parenting plan.”
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