Hensley v. Hensley

2024 Ohio 5751, 258 N.E.3d 735
CourtOhio Court of Appeals
DecidedDecember 9, 2024
DocketCA2024-04-026
StatusPublished
Cited by1 cases

This text of 2024 Ohio 5751 (Hensley v. Hensley) 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
Hensley v. Hensley, 2024 Ohio 5751, 258 N.E.3d 735 (Ohio Ct. App. 2024).

Opinion

[Cite as Hensley v. Hensley, 2024-Ohio-5751.]

IN THE COURT OF APPEALS

TWELFTH APPELLATE DISTRICT OF OHIO

CLERMONT COUNTY

RONALD HENSLEY, : CASE NO. CA2024-04-026 Appellant, : OPINION : 12/9/2024 - vs - :

KRYSTLE HENSLEY, :

Appellee. :

APPEAL FROM CLERMONT COUNTY COURT OF COMMON PLEAS DOMESTIC RELATIONS DIVISION Case No. 2022 DRA 00301

Crowe and Welch, and Robert H. Welch III, for appellant.

The Lampe Law Office, LLC, and Stephen J. Otte, for appellee.

M. POWELL, J.

{¶ 1} Appellant, Ronald Hensley ("Father"), appeals a decision of the Clermont

County Court of Common Pleas, Domestic Relations Division, ordering him to pay child

support to appellee, Krystle Hensley ("Mother").

{¶ 2} The parties were married in 2012 and have two minor children together. On Clermont CA2024-04-026

March 17, 2022, Father filed for divorce. The parties resolved all issues except spousal

support and issues relating to allocation of parental rights and responsibilities. A trial on

these issues was held on September 27-28, 2024. Mother advocated for a shared

parenting plan. Father advised the trial court he could not co-parent with Mother and

asked to be designated sole residential parent and legal custodian of the children. Trial

testimony revealed that Mother has a Bachelor of Science degree in marketing and that

she was primarily a stay-at-home parent during the marriage. At the time of trial, Mother

was employed on a part-time basis as a receptionist at a beauty salon, earning $12.50

an hour, and Father was employed as a product manager at a 3D scanning company,

earning $100,000 a year. Mother testified that she was seeking full-time employment but

that she needed spousal support, child support, or a combination of both in the interim.

{¶ 3} The trial court issued a decision on January 2, 2024; the divorce decree

was journalized the following day. The trial court designated Father sole residential

parent and legal custodian of the children and granted Mother parenting time pursuant to

the trial court's guideline parenting schedule. Under the schedule—a repeating two-week

period—each parent has seven overnights with the children every 14 days, thereby

resulting in equal parenting time. The trial court also designated Father as the obligor

and Mother as the obligee for child support purposes and ordered Father to pay Mother

$1,140.45 a month in child support. The trial court further ordered Father to maintain

medical insurance on the children, to be responsible for all uninsured medical expenses

of the children, and to pay for all their school, extracurricular, and activity expenses. The

trial court declined to award spousal support to Mother.

{¶ 4} Father now appeals, raising one assignment of error:

{¶ 5} THE TRIAL COURT ERRED AS A MATTER OF LAW WHEN IT ORDERED

APPELLANT TO PAY CHILD SUPPORT.

-2- Clermont CA2024-04-026

{¶ 6} Father argues the trial court erred in designating him the child support

obligor and ordering him to pay child support to Mother. Father asserts that as the sole

residential parent and legal custodian of the children, he should have been designated

the child support obligee pursuant to R.C. 3119.07(A) and not required to pay child

support to Mother. In support of his argument, Father cites France v. France, 2011-Ohio-

3025 (1st Dist.). In turn, Mother argues that the trial court acted within its discretion in

ordering Father to pay child support to Mother considering the parties' equal parenting

time and income disparity, and that such an order is in the children's best interests. In

support of her argument, Mother cites Prusia v. Prusia, 2003-Ohio-2000 (6th Dist.);

Bigelow v. Bigelow, 2014-Ohio-994 (6th Dist.); Frey v. Frey, 2007-Ohio-2991 (3d Dist.);

and Kanel v. Kanel, 1989 Ohio App. LEXIS 5065 (8th Dist. Oct. 19, 1989).

{¶ 7} R.C. 3119.07(A) provides

Except when the parents have split parental rights and responsibilities, a parent's child support obligation for a child for whom the parent is the residential parent and legal custodian shall be presumed to be spent on that child and shall not become part of a child support order, and a parent's child support obligation for a child for whom the parent is not the residential parent and legal custodian shall become part of a child support order.

{¶ 8} "Under a plain reading of R.C. 3119.07(A), there is a clear presumption that

the legal custodian and residential parent's child-support obligation is spent on that child

and does not become part of a child-support order where the parties do not have split

parental rights and responsibilities." France at ¶ 16. Stated otherwise, "by operation of

statute, in sole custody arrangements, the parent designated the residential parent and

legal custodian is the child support obligee, i.e., the parent who receives the child support

payments, and the parent not designated the residential parent and legal custodian is the

child support obligor, i.e., the parent who must pay child support." Ash v. Dean, 2016-

-3- Clermont CA2024-04-026

Ohio-5589, ¶ 33 (10th Dist.); MacKnight v. MacKnight, 2022-Ohio-648, ¶ 28 (12th Dist.).

"Split parental rights and responsibilities" applies where "there is more than one child who

is the subject of an allocation of parental rights and responsibilities and each parent is the

residential parent and legal custodian of at least one of those children." R.C.

3119.01(C)(22); Pauly v. Pauly, 80 Ohio St.3d 386, 388, 1997-Ohio-105.

{¶ 9} It is undisputed that the parties do not have split parental rights and

responsibilities or a shared parenting plan and that the trial court designated Father the

sole residential parent and legal custodian of the children. Therefore, under R.C.

3119.07(A), the trial court was required to presume that Father's child-support obligation

was spent on the children as part of his daily spending. France, 2011-Ohio-3025 at ¶ 17.

It follows that the trial court erred in designating Father the obligor and ordering him to

pay child support to Mother. Instead, Mother should have been considered the obligor

because she was the nonresidential parent. Id. at ¶ 17 and 21; Ash at ¶ 34.

{¶ 10} The cases cited by Mother stand for the proposition that a trial court may

order the residential parent and legal custodian to pay child support to the nonresidential,

noncustodial parent if the parents spend an equal amount of time with the children and

the trial court determines that such an order is in the best interest of the children. See

Prusia, 2003-Ohio-2000 at ¶ 32; Bigelow, 2014-Ohio-994 at ¶ 20-21; Frey, 2007-Ohio-

2991 at ¶ 32; and Kanel, 1989 Ohio App. LEXIS 5065 at *5. However, neither Prusia nor

Bigelow nor Kanel analyze, apply, or cite R.C. 3119.07(A). These cases are therefore

not persuasive. While Frey cites R.C. 3119.07(A), it does not analyze or apply the statute.

Rather, in explaining its holding, the court of appeals stated,

[The courts'] approach not only leaves intact the well- established presumption that the residential parent in a typical sole residential parent arrangement expends his or her portion of the annual support obligation sum "directly on the children in providing shelter, food, clothing, and ordinary

-4- Clermont CA2024-04-026

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Cite This Page — Counsel Stack

Bluebook (online)
2024 Ohio 5751, 258 N.E.3d 735, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hensley-v-hensley-ohioctapp-2024.