In re J.D.

Citations

• 2022 Ohio 996

Syllabus

R.C. 3119.83 provides that, except as provided in R.C. 3119.84, a court may not retroactively modify an obligor's duty to pay a delinquent support payment. R.C. 3119.84 permits retroactive modification of child support only for the period between filing a motion for modification and a final order on the motion. Termination of an arrearage is a retroactive modification of child support. The juvenile court did not abuse its discretion in denying Father's motion. Additionally, the juvenile court did not abuse its discretion in finding Father had not demonstrated a change of circumstances and that modification of custody was not in the children's best interests.