Lause v. Lause

2025 Ohio 5670
CourtOhio Court of Appeals
DecidedDecember 19, 2025
DocketWD-25-004
StatusPublished

This text of 2025 Ohio 5670 (Lause v. Lause) 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
Lause v. Lause, 2025 Ohio 5670 (Ohio Ct. App. 2025).

Opinion

[Cite as Lause v. Lause, 2025-Ohio-5670.]

IN THE COURT OF APPEALS OF OHIO SIXTH APPELLATE DISTRICT WOOD COUNTY

Jennifer Lause Court of Appeals No. {87}WD-25-004

Appellee Trial Court No. 2020 DR 0052

v.

Samuel Lause DECISION AND JUDGMENT

Appellant Decided: December 19, 2025

*****

Dorothy L. Williams, for appellee.

Karin L. Coble, for appellant.

SULEK, P.J.

{¶ 1}Appellant Samuel Lause appeals the order of the Wood County Court of

Common Pleas, Domestic Relations Division, denying his request for modification of

child support, reallocation of parental rights, and reallocation of tax dependency. For the

reasons that follow, the trial court’s judgment is affirmed, in part, and reversed, in part.

I. Factual Background and Procedural History

{¶ 2}Samuel and appellee Jennifer Lause were married on July 30, 2015. They

have one child, W.L., born of the marriage. On May 5, 2022, the parties divorced. In the judgment entry, Jennifer was designated the residential parent and legal custodian of

W.L., and the parties shared parenting time.

{¶ 3}Relevant here, significant testimony was taken during the divorce

proceedings regarding the parties’ preferences and practices for seeking medical

treatment when W.L. was sick. Jennifer preferred limited medical intervention, choosing

instead to utilize home remedies and treatments. In one instance, in November 2019,

W.L. was sick for approximately three weeks. At Samuel’s urging, Jennifer took W.L. to

the doctor, who diagnosed her with a virus and recommended that the parents let it run its

course. W.L. has a listed pediatrician but does not receive regular well-check

appointments. She also did not see the dentist. At the time of the divorce, neither party

provided health insurance for W.L. and she was not on Medicaid.

{¶ 4}The parties also testified concerning W.L.’s education. W.L. was entering

kindergarten and Jennifer wanted to homeschool her, noting that she had homeschooled

her older son and Samuel had experience homeschooling as well. Samuel has an older

daughter, D.L., who has down syndrome and who receives in-home instruction from a

teacher paid by the state. Samuel preferred that W.L. attend a formal school, explaining

that it would be difficult for Jennifer to homeschool while she worked full-time. Jennifer

responded that kindergarten only takes a couple of hours.

{¶ 5}Another issue addressed during the divorce was child support. Samuel was

not working at the time of the divorce. Previously, he had been a union crane operator,

earning $70,000 in 2017, $90,000 in 2018, and $100,000 in 2019. He stopped working in

2. March or April of 2020, around the time the divorce complaint was filed, and went on

unemployment. Before taking unemployment benefits, Samuel was on pace to earn

between $65,000 and $85,000 that year. Samuel testified that although he was not

“disabled,” his lower back problems and diverticulitis prevented him from working again

as a crane operator. It was noted that he sought to work as a car mechanic from his

home, but was having difficulty obtaining clients. Jennifer worked full-time at Lowe’s,

earning approximately $31,000 per year. She also earned approximately $4,000 per year

making and selling cakes.

{¶ 6}In determining the appropriate amount of child support, the trial court found

that Samuel was voluntarily underemployed and determined that his earning capacity was

$80,000 annually. It reduced that amount, however, and only imputed an income of

$40,000 annually to Samuel because “[h]e has some objective reasons for either working

limited hours or incurring expense for [D.L.’s] care. This imputation allows for the cost

of care for [D.L.] while working, and for [W.L.’s] presence in Sam’s home on the days

the [guardian ad litem] recommended.”

{¶ 7}As a final relevant matter, the trial court determined that Jennifer would

claim W.L. as a dependent on her taxes. The trial court recognized a presumption in

favor of awarding the tax exemption to the residential parent and found that Samuel did

not present sufficient evidence—such as proof of net tax savings—to allow it to find

allocating the right to Samuel to claim W.L. as a dependent was in the child’s best

interest.

3. {¶ 8}Neither party appealed the judgment entry of divorce.

{¶ 9}Seven months later, on December 9, 2022, Samuel filed a pro se motion to

(1) get full custody, (2) reduce child support, and (3) claim W.L. every other year on his

taxes. Two months after that, on February 9, 2023, he filed a pro se motion for a change

of parental rights and responsibilities.

{¶ 10}On September 29, 2023, the trial court held a hearing on Samuel’s motions.

Samuel first presented testimony that his older daughter, D.L., qualifies for part-time

caregiver services through the Wood County Board of Developmental Disabilities paid

for by Medicaid. The department has been working with the family for several years, but

is currently unable to locate a provider of those caregiver services.

{¶ 11}Samuel then testified. He stated that he lives in the “country home” in

which W.L. was born. It has goats, chickens, and other pets and he described it as the

only home that W.L. knows.

{¶ 12}He wants to have full custody of W.L. not because he wants to take W.L.

from Jennifer, but because he believes it would be better for W.L.’s health and education.

He described that W.L. is a very bright child who will turn seven years old in a few

months and who should be in first grade, but he noted that she did not know how to read

or how to write numbers above 10. Samuel believes she is not receiving enough

education since Jennifer is busy working two jobs and he is busy working on customers’

cars. He stated that he tries to homeschool to the best of his ability, and he teaches W.L.

and D.L. at the same time. If he has W.L. for two days, he tries to do a total of three

4. hours of education with her. He would prefer that W.L. go to a small private school or at

least do online virtual schooling.

{¶ 13}Regarding W.L.’s health, Samuel testified that she only had been to the

doctor once in her life when he demanded that Jennifer take her in November 2019.

Samuel also stated that she had needed extensive dental work. He took her to the Wood

County Health Department, but the work was too much for them, and they referred him

to UT Dental in the Toledo Hospital. Jennifer refused to allow Samuel to pick W.L. up

for the dental appointment. W.L. was then placed on a call list and Jennifer later agreed

to allow him to take W.L. when UT Dental called with an opening. W.L. needed three

crowns, one tooth pulled, and two fillings.

{¶ 14}As to his financial situation, Samuel runs his own auto mechanic business

out of his house. He does so because it allows him to be home to care for and

homeschool his children. He estimates that he works approximately 25 hours a week

because of his time spent taking care of his children. He testified that he only has W.L.

when he also has D.L. and it helps because the girls can look after one another. He

further described that he has diverticulitis and lower back pain, commenting that his “L-5

disk is gone.” He stated that he was physically capable of returning to work as a crane

operator, but it would be detrimental for his health.

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