Phelps v. Saffian

Citations

• 2018 Ohio 4329

Syllabus

Motion to modify child support change in circumstances combined gross income more than $150,000 R.C. 3119.04(B) imputation of income retroactive award R.C. 3105.73(B) attorney fees civil contempt. On remand, trial court did not abuse its discretion in increasing father's child support obligation due to a substantial change in circumstances. However, trial court's order imposing modified child support retroactive to date mother filed motion to modify violated appellate court's mandate. Trial court did not abuse its discretion in awarding mother $38,855 toward her attorney fees under R.C. 3105.73(B). Trial court did not abuse its discretion in finding father to be in contempt of court where record supported finding that father had repeatedly failed to comply with court orders to produce financial documentation. Case remanded for issuance of a new child support order that imposes modified child support obligation retroactive to August 17, 2011 and for recalculation of child support arrearages.