Notes of Decisions
Cited in
36
cases (
12 in the last 5 years), 2005–2026 · leading case:
Hess v. Ugorec, 2021 Ohio 189 (Ohio Ct. App. 2021).
Hess v. Ugorec, 2021 Ohio 189 (Ohio Ct. App. 2021).
· cites it 10× “{¶17} Here, the trial court found that it “retained jurisdiction over the matter” and pursuant to R.C. 3119.86 and the magistrate’s review of the case, “it was determined that child support would continue due to [S.”
In re Palcisco, 2012 Ohio 6134 (Ohio Ct. App. 2012).
· cites it 11× “{¶11} A domestic relations court’s continuing jurisdiction to order child support beyond a child’s eighteenth birthday is set forth in R.C. 3119.86: (A) Notwithstanding section 3109.”
Clay v. Clay, 2022 Ohio 1728 (Ohio Ct. App. 2022).
· cites it 11× “) (finding trial court lacked jurisdiction to award custody and order child support for child that had physical and developmental disabilities since birth, reasoning that neither Castle nor R.C. 3119.86 applied where the child was over the age of eighteen at the time of the…”
Brown v. Brown, 2025 Ohio 1998 (Ohio Ct. App. 2025).
· cites it 34× “Here, however, appellant argues the trial court erred in its application of R.C. 3119.86 to conclude it lacked jurisdiction to enter a child support order for a Castle child.”
Lorain Cty Child. Servs. v. Gossick, 2014 Ohio 3865 (Ohio Ct. App. 2014).
· cites it 3× “R.C. 3119.86(A) carves out very limited exceptions to the general rule that child support orders shall terminate upon the child’s eighteenth birthday.”
In re R.B., 2013 Ohio 2392 (Ohio Ct. App. 2013).
· cites it 3× “should be continued pursuant to R.C. 3119.86. R.C. 3119.86 permits child support to continue past the child's 19th birthday if the child is "mentally or physically disabled and is incapable of supporting or maintaining himself or herself.”
C.S. v. R.S., 2021 Ohio 3581 (Ohio Ct. App. 2021).
· cites it 3× “), paragraph two of the syllabus ("domestic relations court retains jurisdiction over parties in a divorce, dissolution or separation proceeding to continue or to modify support payments for a mentally or physically disabled child, who was so disabled before he or she attained…”
Ravenstein v. Ravenstein, 167 So. 3d 210 (Miss. 2014).
“2d 259 (1968)); Ohio Rev. Code Ann. § 3119.86 (A)(1)(a) (codifying Castle v.”
Brilla v. Mulhearn, 859 N.E.2d 578 (Ohio Ct. App. 2006).
“Subsequently, CSEA recommended, pursuant to R.C. 3119.86, that child support for John was to terminate on June 5, 2005.”
Hays v. Alexander, 114 So. 3d 704 (Miss. 2013).
“2(6); Ohio Rev.Code Ann. § 3119.86(A)(1); Okla.”
Baker v. Baker, 2013 Ohio 1816 (Ohio Ct. App. 2013).
“The holding in Castle has been codified in R.C. 3119.86(A)(1)(a). {¶ 27} In arguing that Brian should be emancipated, Daniel focuses on the fact that the child involved in Castle had “a mental age of five years, is attending a special school on a full-time basis and will never…”
Gatchel v. Gatchel, 824 N.E.2d 576 (Ohio Ct. App. 2005).
“Therefore, we determine that an approved home-education program becomes the legal equivalent of attending a public, private, or parochial school for purposes of a child-support obligation under R.C. 3119.86. {¶ 20} Accordingly, since Nathan’s home-education program operates…”
— Ohio Rev. Code § 3119.86(A) — 7 cases
In re Palcisco, 2012 Ohio 6134 (Ohio Ct. App. 2012).
“{¶11} A domestic relations court’s continuing jurisdiction to order child support beyond a child’s eighteenth birthday is set forth in R.C. 3119.86: (A) Notwithstanding section 3109.”
Lorain Cty Child. Servs. v. Gossick, 2014 Ohio 3865 (Ohio Ct. App. 2014).
“R.C. 3119.86(A) carves out very limited exceptions to the general rule that child support orders shall terminate upon the child’s eighteenth birthday.”
Clay v. Clay, 2022 Ohio 1728 (Ohio Ct. App. 2022).
“) (finding trial court lacked jurisdiction to award custody and order child support for child that had physical and developmental disabilities since birth, reasoning that neither Castle nor R.C. 3119.86 applied where the child was over the age of eighteen at the time of the…”
— Ohio Rev. Code § 3119.86(A)(1) — 9 cases
Hess v. Ugorec, 2021 Ohio 189 (Ohio Ct. App. 2021).
“{¶17} Here, the trial court found that it “retained jurisdiction over the matter” and pursuant to R.C. 3119.86 and the magistrate’s review of the case, “it was determined that child support would continue due to [S.”
Hays v. Alexander, 114 So. 3d 704 (Miss. 2013).
“2(6); Ohio Rev.Code Ann. § 3119.86(A)(1); Okla.”
Brown v. Brown, 2025 Ohio 1998 (Ohio Ct. App. 2025).
“Here, however, appellant argues the trial court erred in its application of R.C. 3119.86 to conclude it lacked jurisdiction to enter a child support order for a Castle child.”
— Ohio Rev. Code § 3119.86(A)(1)(a) — 12 cases
Hess v. Ugorec, 2021 Ohio 189 (Ohio Ct. App. 2021).
“{¶17} Here, the trial court found that it “retained jurisdiction over the matter” and pursuant to R.C. 3119.86 and the magistrate’s review of the case, “it was determined that child support would continue due to [S.”
Baker v. Baker, 2013 Ohio 1816 (Ohio Ct. App. 2013).
“The holding in Castle has been codified in R.C. 3119.86(A)(1)(a). {¶ 27} In arguing that Brian should be emancipated, Daniel focuses on the fact that the child involved in Castle had “a mental age of five years, is attending a special school on a full-time basis and will never…”
Lorain Cty Child. Servs. v. Gossick, 2014 Ohio 3865 (Ohio Ct. App. 2014).
“R.C. 3119.86(A) carves out very limited exceptions to the general rule that child support orders shall terminate upon the child’s eighteenth birthday.”
Clay v. Clay, 2022 Ohio 1728 (Ohio Ct. App. 2022).
“) (finding trial court lacked jurisdiction to award custody and order child support for child that had physical and developmental disabilities since birth, reasoning that neither Castle nor R.C. 3119.86 applied where the child was over the age of eighteen at the time of the…”
In re R.B., 2013 Ohio 2392 (Ohio Ct. App. 2013).
“should be continued pursuant to R.C. 3119.86. R.C. 3119.86 permits child support to continue past the child's 19th birthday if the child is "mentally or physically disabled and is incapable of supporting or maintaining himself or herself.”
— Ohio Rev. Code § 3119.86(A)(1)(b) — 3 cases
Hess v. Ugorec, 2021 Ohio 189 (Ohio Ct. App. 2021).
“{¶17} Here, the trial court found that it “retained jurisdiction over the matter” and pursuant to R.C. 3119.86 and the magistrate’s review of the case, “it was determined that child support would continue due to [S.”
— Ohio Rev. Code § 3119.86(A)(1)(c) — 4 cases
Hess v. Ugorec, 2021 Ohio 189 (Ohio Ct. App. 2021).
“{¶17} Here, the trial court found that it “retained jurisdiction over the matter” and pursuant to R.C. 3119.86 and the magistrate’s review of the case, “it was determined that child support would continue due to [S.”
— Ohio Rev. Code § 3119.86(A)(2) — 2 cases
Lorain Cty Child. Servs. v. Gossick, 2014 Ohio 3865 (Ohio Ct. App. 2014).
“R.C. 3119.86(A) carves out very limited exceptions to the general rule that child support orders shall terminate upon the child’s eighteenth birthday.”
— Ohio Rev. Code § 3119.86(B) — 5 cases
In re Palcisco, 2012 Ohio 6134 (Ohio Ct. App. 2012).
“{¶11} A domestic relations court’s continuing jurisdiction to order child support beyond a child’s eighteenth birthday is set forth in R.C. 3119.86: (A) Notwithstanding section 3109.”
Clay v. Clay, 2022 Ohio 1728 (Ohio Ct. App. 2022).
“) (finding trial court lacked jurisdiction to award custody and order child support for child that had physical and developmental disabilities since birth, reasoning that neither Castle nor R.C. 3119.86 applied where the child was over the age of eighteen at the time of the…”
— Ohio Rev. Code § 3119.86(C) — 1 case
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