Fraelich v. Parrish

2016 Ohio 445
CourtOhio Court of Appeals
DecidedFebruary 8, 2016
Docket14CA010684
StatusPublished
Cited by2 cases

This text of 2016 Ohio 445 (Fraelich v. Parrish) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Fraelich v. Parrish, 2016 Ohio 445 (Ohio Ct. App. 2016).

Opinion

[Cite as Fraelich v. Parrish, 2016-Ohio-445.]

STATE OF OHIO ) IN THE COURT OF APPEALS )ss: NINTH JUDICIAL DISTRICT COUNTY OF LORAIN )

MICHAEL FRAELICH C.A. No. 14CA010684

Appellee

v. APPEAL FROM JUDGMENT ENTERED IN THE DONNA PARRISH COURT OF COMMON PLEAS COUNTY OF LORAIN, OHIO Appellant CASE No. 12JB27805

DECISION AND JOURNAL ENTRY

Dated: February 8, 2016

WHITMORE, Judge.

{¶1} Appellant Donna Parrish (“Mother”) and Appellee Michael Fraelich (“Father”)

are the unmarried parents of a young son. Mother appeals from the order of the Lorain County

Juvenile Court establishing child support to be paid by Father. We reverse in part and affirm in

part.

I

{¶2} Mother and Father lived together but were never married. Mother terminated the

relationship and Father moved out of their shared residence a few weeks after Mother informed

Father that she was pregnant. Mother refused to communicate with Father throughout the

pregnancy and following the birth of the child.

{¶3} Father promptly filed a complaint to establish parentage and allocate parental

rights and responsibilities in the juvenile court. Genetic testing proved Father to be the

biological parent of the child. 2

{¶4} Mother filed a motion to establish child support. Mother moved “for an [o]rder

directing [Father] to pay monetary support for the parties’ child.” Mother “further move[d] for

an [o]rder directing [Father] to share in the child’s uncovered birthing expenses and past care

retroactive to the child’s date of birth * * *.”

{¶5} The case proceeded to trial on Father’s complaint and Mother’s motion to

establish child support. The court issued a judgment entry establishing a shared parenting plan

and ordering child support. The order required Father to pay child support prospectively, but did

not address the issues of retroactive support and payment of uncovered birthing expenses. The

order granted Father a 43% downward deviation in support based upon the fact that Father

eventually would have custody 43% of the time. The court also found that the deviation was

warranted based on the disparity in the parties’ incomes.

{¶6} Mother appeals from the trial court’s award of child support. She raises two

assignments of error for our review.

II

Assignment of Error Number One

THE TRIAL COURT COMMITTED REVERSIBLE ERROR WHEN IT FAILED TO ORDER THAT THE APPELLEE/FATHER PAY CHILD SUPPORT FOR THE PERIOD STARTING FROM THE BIRTH OF THE SUBJECT CHILD ON NOVEMBER 16, 2012, TO THE DATE OF ISSUANCE OF ITS DECISION ON SEPTEMBER 26, 2014.

{¶7} In her first assignment of error, Mother argues that the trial court erred when it

failed to order Father to pay child support from the child’s birth date until the date of its decision.

Mother does not appeal the trial court’s failure to order payment of uncovered birthing expenses.

Because the trial court did not address Mother’s motion for past child support when it disposed

of the issues in Father’s complaint, Mother’s motion for retroactive support is deemed denied. 3

See Wolford v. Sanchez, 9th Dist. Lorain No. 05CA008674, 2005-Ohio-6992, ¶ 41 (“motions not

ruled upon are deemed denied”). We agree that the trial court erred when it denied Mother’s

request for retroactive support.

{¶8} “[A] trial court’s decision regarding child support obligations falls within the

discretion of the trial court and will not be disturbed absent a showing of an abuse of discretion.”

Pauly v. Pauly, 80 Ohio St.3d 386, 390 (1997), citing Booth v. Booth, 44 Ohio St.3d 142, 144

(1989). An abuse of discretion is more than an error of judgment; it connotes a decision that is

unreasonable, arbitrary, or unconscionable. Blakemore v. Blakemore, 5 Ohio St.3d 217, 219

(1983). When applying the abuse of discretion standard, an appellate court may not substitute its

judgment for that of the trial court. Berk v. Matthews, 53 Ohio St.3d 161, 169 (1990).

{¶9} This Court has held that “it is the law of Ohio that the adjudicated natural parent

of an illegitimate child has the duty to support such child from birth.” In re Adoption of Taylor,

61 Ohio App.3d 500, 503 (9th Dist.1989), citing Baugh v. Carver, 3 Ohio App.3d 139 (1st

Dist.1981). Section R.C. 3111.13 of the Ohio Revised Code sets forth what may be included in a

judgment in a parentage action. Under R.C. 3111.13(C), a judgment may include “any other

provision directed against the appropriate party to the proceeding, concerning the duty of support

* * *.” “Section 3111.13(C) is broad enough to allow a child support award to be made

retroactive to the date of birth of the child.” Magee v. Robinson, 9th Dist. Summit No. 18896,

1998 WL 646677, * 2 (Sept. 16, 1998).

{¶10} Under R.C. 3111.13(F)(2), it is mandatory that the trial court consider “all

relevant factors” in determining whether to award support for the period prior to a determination

of parentage. R.C. 3111.13(F)(2) provides, in part:

[The court] shall consider all relevant factors, including, but not limited to, any monetary contribution either parent of the child made to the support of the child 4

prior to the court issuing the order requiring the parent to pay an amount for the current support of the child.

{¶11} In this matter, Father argues that the court was within its discretion to deny

retroactive child support on the basis of Mother’ derisive behavior. Father cites Mother’s

deliberate lack of communication with Father regarding the child, and Mother’s apparent

intentional disregard of court orders and deadlines to complete the genetic testing necessary to

establish Father’s parentage.

{¶12} Father’s argument implies that a court may deny retroactive child support as a

punitive measure. He fails to consider that, under these circumstances, denying support as a

punitive measure punishes the child along with the offending parent. Rather than penalize the

child, the court could have addressed Mother’s behavior directly through a contempt citation. We

do not resolve the merits of Father’s argument here, however. Because the court failed to

address Mother’s request for retroactive support in any respect, we do not know if the court in

fact considered Mother’s behavior when it failed to award back support for the period prior to the

determination of parentage.

{¶13} Here, the court did not state what factors it considered under R.C. 3111.13(F)(2)

to deny retroactive child support. Nor did it make any findings of fact that would support the

decision. The court therefore abused its discretion in failing to award past support without

demonstrating circumstances that justify relieving Father of his duty to support his child from

birth. See Magee, 1998 WL 646677 at * 2, citing Baugh, 3 Ohio App.3d at 141. Mother’s first

assignment of error is sustained.

Assignment of Error Number Two

THE TRIAL COURT COMMITTED REVERSIBLE ERROR BY GRANTING THE APPELLANT/FATHER A DOWNWARD DEVIATION FROM THE CHILD SUPPORT GUIDELINES IN HIS CHILD SUPPORT OBLIGATION IN 5

THE AMOUNT OF 43%, BASED PRIMARILY UPON THE FACT THAT ITS ORDER OF POSSESSION ULTIMATELY PLACES THE CHILD WITH HIM FOR 43% OF THE TIME.

{¶14} In her second assignment of error, Mother contends that the court erred when it

granted Father a 43% downward deviation from the Ohio child support guidelines based on

Father’s custodial time with the child. We disagree.

{¶15} R.C. 3119.02 governs the calculation of child support.

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