Kemmler v. Kemmler

2025 Ohio 4516
CourtOhio Court of Appeals
DecidedSeptember 29, 2025
Docket10-25-06
StatusPublished

This text of 2025 Ohio 4516 (Kemmler v. Kemmler) 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
Kemmler v. Kemmler, 2025 Ohio 4516 (Ohio Ct. App. 2025).

Opinion

[Cite as Kemmler v. Kemmler, 2025-Ohio-4516.]

IN THE COURT OF APPEALS OF OHIO THIRD APPELLATE DISTRICT MERCER COUNTY

JAMES E. KEMMLER, CASE NO. 10-25-06 PLAINTIFF-APPELLANT,

v.

PEGGY A. KEMMLER, OPINION AND JUDGMENT ENTRY DEFENDANT-APPELLEE.

Appeal from Mercer County Common Pleas Court Domestic Relations Division Trial Court No. 21-DIV-042

Judgment Reversed and Cause Remanded

Date of Decision: September 29, 2025

APPEARANCES:

Brian A. Kruse for Appellant

Jonathan A. Rich for Appellee Case No. 10-25-06

WILLAMOWSKI, J.

{¶1} Plaintiff-appellant James E. Kemmler (“James”) appeals the judgment

of the Domestic Relations Division of the Mercer County Court of Common Pleas,

arguing that the trial court erred in denying his motion to terminate a withholding

order that applies to his spousal support obligation to Peggy A. Kemmler (“Peggy”).

For the reasons set forth below, the judgment of the trial court is reversed.

Facts and Procedural History

{¶2} James and Peggy were married in 2002. On July 7, 2021, James filed a

complaint for divorce. At this time, Peggy and James had one minor child. On

January 27, 2023, the trial court issued a judgment entry of divorce in which James

was ordered to pay child support in the amount of $8,000.00 a month. He was also

ordered to pay spousal support in the amount “of Seventeen Thousand Dollars

($17,000.00) per month, plus 2% processing charge, for a term of sixty-three (63)

months . . . .” (Doc. 185). The trial court reserved jurisdiction over the amount and

duration of the spousal support award.

{¶3} On January 13, 2025, James filed a motion to terminate the withholding

order (“motion to terminate”) that required him to make spousal support payments

through the child support enforcement agency (“CSEA”) and to incur a two percent

processing charge. Instead, he sought an order that would permit him to make

spousal support payments directly to Peggy. In this motion, James pointed out that

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he no longer had a child support obligation since his child had reached the age of

majority. For this reason, he argued that paying a spousal support obligation

through the CSEA was unnecessary and that CSEA’s two percent processing fee

was costing him $4,080.00 annually.

{¶4} On January 27, 2025, Peggy filed a brief in opposition to James’s

motion to terminate. On January 30, 2025, the trial court denied James’s motion to

terminate. The judgment entry stated that James had not offered “any valid reason”

in support of his motion. (Doc. 384). For this reason, the judgment entry simply

imposed its “common practice [of] . . . issu[ing] withholding orders for all child

support and spousal support payments unless agreed to otherwise by both parties.”

(Doc. 384).

{¶5} James filed his notice of appeal on March 3, 2025. On appeal, he raises

the following two assignments of error:

First Assignment of Error

The trial court erred in finding Husband agreed to withholding order for spousal support for the entirety of the spousal support term.

Second Assignment of Error

The trial court abused its discretion by failing to find Husband provided a valid reason to terminate the withholding order.

We will consider these two assignments of error in one analysis.

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First and Second Assignments of Error

{¶6} James argues that the stated grounds for denying his motion to terminate

were not reasonable and constituted an abuse of discretion.

Legal Standard

{¶7} R.C. 3121.441 addresses the direct payment of spousal support and

reads, in its relevant part, as follows:

(A) . . . . when a court pursuant to . . . [R.C.] 3105.18 . . . issues or modifies an order requiring an obligor to pay spousal support . . . ., or at any time after the issuance, granting, or modification of an order or decree of that type, the court may permit the obligor to make the spousal support payments directly to the obligee instead of to the office if the obligee and the obligor have no minor children born as a result of their marriage . . . .

...

(C) If a court permits an obligor to make spousal support payments directly to an obligee pursuant to division (A) of this section and the obligor is in default in making any spousal support payment to the obligee, the court, upon motion of the obligee or on its own motion, may rescind the permission granted under that division. . . . .

(Emphasis added). “[T]here is no requirement that the court ‘conduct an analysis

of an obligor’s possible failure to comply with a direct payment order’ before

deciding whether to allow direct payments.” Salpietro v. Salpietro, 2023-Ohio-169,

¶ 49 (6th Dist.), quoting Dingey v. Dingey, 2020-Ohio-5340, ¶ 38 (5th Dist.).

Standard of Review

{¶8} Where applicable, R.C. 3121.441(A) grants trial courts the discretion to

permit or deny direct spousal support payments. Dingey at ¶ 38; Allen v. Allen,

-4- Case No. 10-25-06

2022-Ohio-3198, ¶ 83 (11th Dist.). For this reason, appellate courts review a

decision about whether to permit direct spousal support payments under an abuse of

discretion standard. Salpietro at ¶ 50.

Legal Analysis

{¶9} In this case, the trial court denied James’s motion without a hearing on

this matter. Thus, our only available insight into the trial court’s reasoning is the

content of its judgment entry denying the motion to terminate. As the first basis for

denying the motion to terminate, the trial court stated that James and his attorney

“agreed to said withholding of spousal support, including the processing charge, and

acknowledged the same via their signatures on the January 27, 2023 Judgment

Entry” of Divorce. (Doc. 384).

{¶10} On appeal, James asserts that this initial justification incorrectly relies

upon characterizing his signature on the judgment entry of divorce as an agreement

to make spousal support payments through the CSEA for the duration of his spousal

support obligation. He points out that R.C. 3121.441(A) “permit[s] the obligor to

make the spousal support payments directly to the obligee . . . if the obligee and

obligor have no minor children . . . .” (Emphasis added).

{¶11} Based on this statutory language, James contends that the option to

make direct payments, as provided for in R.C. 3121.441(A), was not available at the

time of his divorce because he had a spousal support obligation and a child support

obligation to his minor child. He argues that his signature on the judgment entry

-5- Case No. 10-25-06

simply acknowledged this legal reality.1 After his child reached the age of majority

and his child support obligation terminated, James sought to make direct spousal

support payments to Peggy as permitted by R.C. 3121.441(A).

{¶12} The contents of the judgment entry of divorce do not suggest that, in

signing this entry, James was agreeing to make payments through the CSEA for the

duration of his spousal support obligation or was forfeiting his statutory right to seek

the use of direct payments after he no longer had a minor child. Thus, the first basis

given for denying James’s motion is not substantiated by the record.

{¶13} As the second basis for denying the motion to terminate, the trial court

stated that James “ha[d] not provided any valid reason” for terminating the

withholding order. (Doc. 384).

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Related

Dingey v. Dingey
2020 Ohio 5340 (Ohio Court of Appeals, 2020)
Allen v. Allen
2022 Ohio 3198 (Ohio Court of Appeals, 2022)
Salpietro v. Salpietro
2023 Ohio 169 (Ohio Court of Appeals, 2023)

Cite This Page — Counsel Stack

Bluebook (online)
2025 Ohio 4516, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kemmler-v-kemmler-ohioctapp-2025.