McKenna v. McKenna

Citations

• 2021 Ohio 3188

Syllabus

DIVORCE – SPOUSAL SUPPORT – MODIFICATION: The trial court did not abuse its discretion in modifying husband's spousal-support obligation based on a change in circumstances under R.C. 3105.18(F): Although husband filed his motion to modify spousal support within a short time after the divorce decree, a period of two years passed between the modification motion and the evidentiary hearing, so that the trial court heard evidence from both parties' accountants regarding husband's income for the time period between the filing of the decree and the hearing and husband presented evidence of his declining income from the years 2017-2019, which were not taken into account by the trial court when establishing the original support order.