Lawler v. Green

2024 Ohio 2046
CourtOhio Court of Appeals
DecidedMay 22, 2024
Docket23CA10
StatusPublished

This text of 2024 Ohio 2046 (Lawler v. Green) 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
Lawler v. Green, 2024 Ohio 2046 (Ohio Ct. App. 2024).

Opinion

[Cite as Lawler v. Green, 2024-Ohio-2046.] IN THE COURT OF APPEALS OF OHIO FOURTH APPELLATE DISTRICT PICKAWAY COUNTY

MICHAEL LAWLER, :

Plaintiff-Appellant, : CASE NO. 23CA10

v. :

BROOKLYN GREEN, : DECISION AND JUDGMENT ENTRY

Defendant-Appellee. :

________________________________________________________________

APPEARANCES:

Evan N. Wagner, Dublin, Ohio, for Appellant.

Brooklyn Green, pro se1.

Thelma C. Fosselman, Attorney for Pickaway County Job and Family Services, Division of Child Support, Circleville, Ohio, for Appellee. _______________________________________________________________ CIVIL CASE FROM COMMON PLEAS COURT, JUVENILE DIVISION DATE JOURNALIZED:5-22-24 ABELE, J.

{¶1} This is an appeal from a Pickaway County Common Pleas

Court, Juvenile Division, judgment that found Michael Lawler,

plaintiff below and appellant herein, in contempt of court for

the failure to pay child support.

{¶2} Appellant assigns one error for review.

“THE TRIAL COURT ABUSED ITS DISCRETION BY

1 Appellee did not file a brief and did not participate in this appeal. 2 PICKAWAY, 23CA10

FINDING APPELLANT IN CONTEMPT OF COURT FOR FAILING TO PAY CHILD SUPPORT BECAUSE APPELLANT PRESENTED COMPETENT, CREDIBLE EVIDENCE AND/OR LEGALLY SUFFICIENT EVIDENCE ESTABLISHING APPELLANT’S INABILITY TO PAY.”

{¶3} Appellant, biological father of minor K.B., and mother

Brooklyn Green, appellee, entered into a shared parenting

agreement on June 7, 2018, that established, inter alia,

appellant’s obligation to pay $238.64 per month child support.

{¶4} On September 19, 2022, the Pickaway County Child

Support Enforcement Agency (PCCSEA) filed an Administrative

Adjustment Recommendation that (1) required appellant, obligor,

to pay $449.98 child support per month, (2) presumed appellee,

obligee, to be the appropriate parent to provide health

insurance coverage for the child, and (3) required that when

health insurance coverage becomes available to obligor at a

reasonable cost, the obligor shall inform the agency and may

seek a modification of the health care recommendation.

After ancillary proceedings on other issues, the matter

came on for a hearing before a magistrate on appellant’s

objections to the Administrative Adjustment Recommendation.

After the hearing, the magistrate found that because appellant

failed to establish his service-related Veterans Administration

(VA) benefits are “means-tested,” the child support calculation 3 PICKAWAY, 23CA10

should include the total amount of the veteran’s benefits. The

controlling statute is R.C. 3119.01(C)(12):

Gross income” means, except as excluded in division (C)(1) of this section, the total of all earned and unearned income from all sources during a calendar year, whether or not the income is taxable, and includes income from * * * benefits that are not means-tested and that are received by and in the possession of the veteran who is the beneficiary for any service-connected disability under a program or law administered by the United States department of veterans’ affairs or veterans’ administration;

Further, the statute excludes the following from gross income:

“Gross income” does not include any of the following: (a) Benefits received from means-tested government administered programs, including Ohio works first; prevention, retention, and contingency; means-tested veterans’ benefits;

(b) Benefits for any service-connected disability under a program or law administered by the United States department of veterans’ affairs or veterans’ administration that are not means-tested, that have not been distributed to the veteran who is the beneficiary of the benefits, and that are in the possession of the United States department of veterans affairs or veterans’ administration;

{¶5} The magistrate stated that the threshold issue

revolves around characterizing plaintiff’s VA disability

benefits. As a general rule, non-means-tested benefits are

included in gross income to calculate child support, but the

statute excludes non-means-tested benefits that have not yet

been distributed to a veteran and that are in the VA’s 4 PICKAWAY, 23CA10

possession. The magistrate cited a Second District case that

held that the magistrate had erred when excluding VA disability

benefits from the obligor’s gross income because the evidence in

that record did not show that met it the exclusion requirements.

Mossing-Landers v. Landers, 2016-Ohio-7625, 70 N.E.3d 1060 (2d

Dist.). In the case at bar, the magistrate found that in light

of Landers, appellant failed to establish that his service-

related disability benefits are “means-tested” or meet the

exclusion in R.C. 3119.01(C)(12)(b). Thus, the magistrate

included the total amount of appellant’s service-related

disability benefits in its calculation.

{¶6} After determining that the agency did not err in its

calculation, the magistrate examined the obligee’s offer for a

support deviation. The magistrate noted that the statutory

guideline in this case would be $422.38 per month for current

child support and $18.78 per month for current cash medical

support, for a total of $449.98 per month. The magistrate noted

a significant increase from the original order of $238.64 per

month, and further noted that the order “was effective 4/13/18,

however, Obligor has not paid anything on this order since

inception. An arrears repayment order was added to this figure.

Arrears are now nearly $10,000.” 5 PICKAWAY, 23CA10

{¶7} Consequently, the magistrate found that a deviation is

in the child’s best interests based on the obligee’s knowing and

voluntary request and the court’s modification of the income tax

dependency benefit. Thus, the magistrate recommended that (1)

the obligee be entitled to claim the minor child as a dependent

for income tax purposes every year commencing in 2023, and “a

deviation to $200 per month, plus processing fees, cash medical

support and arrears repayment, would be warranted.”

Consequently, the magistrate recommended (1) the effective date

of these orders be October 1, 2022, (2) obligor shall pay $200,

plus processing charge, per month, for current child support,

and $18.78, plus processing charge, per month, for cash medical

support, for a total of $223.16 per month, (3) obligor shall

repay arrears for current child support at a rate of $20 per

month, plus processing fees, and for cash medical support at the

rate of $1.88 per month, plus processing fees.

{¶8} Subsequently, PCCSEA asked the trial court to find

appellant in contempt for his failure to comply with the court’s

April 13, 2018 child support order. In addition, appellant

objected to the magistrate’s January 4, 2023 recommendation.

The trial court’s March 13, 2023 hearing addressed both the

appellant’s objections and PCCSEA’s contempt motion. 6 PICKAWAY, 23CA10

{¶9} At the hearing, Pickaway County Juvenile and Family

Services and Child Support Division Case Manager Cleresa Brust

testified that she reviewed appellant’s payment history for the

past 12 months and brought a copy of the pay record from the

beginning of the child support order. Brust indicated that the

current monthly obligation totaled $286.37 and appellant’s “past

due unpaid balance is $10,610.53 * * * through February 28,

2023.” Appellant made “zero payments in the past 12 months,”

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Bluebook (online)
2024 Ohio 2046, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lawler-v-green-ohioctapp-2024.