Mangen v. Mangen

Citations

• 2021 Ohio 3693

Syllabus

The trial court recalculated appellant's child support obligation after the emancipation of the parties' older child. The trial court did not abuse its discretion in considering the R.C. 3119.23 and R.C. 3119.24 shared parenting child support factors. However, since appellant has parenting time with the remaining child in excess of 147 nights per year, he is entitled to a mandatory 10% child support deviation under R.C. 3119.051 and to consideration of an additional deviation under R.C. 3119.231(A) if an additional deviation is not granted, the trial court must set forth the factual basis for this denial pursuant to R.C. 3119.231(B). The trial court committed plain error because it either did not consider the additional deviation under R.C. 3119.231(A) or it did not order the mandatory deviation required by R.C. 3119.051. Judgment reversed and remanded.