Lowman v. Nelligan

Ohio Court of Appeals·Decided August 19, 2026·No. 31669·Published

Opinion

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

MARK W. LOWMAN C.A. No. 31669 Appellant

v. APPEAL FROM JUDGMENT ENTERED IN THE

KATHLEEN A. NELLIGAN COURT OF COMMON PLEAS COUNTY OF SUMMIT, OHIO

Appellee CASE No. DR-2020-11-2832

DECISION AND JOURNAL ENTRY Dated: August 19, 2026

SUTTON, Judge.

{¶1} Plaintiff-Appellant Mark W. Lowman appeals the judgment of the Summit County Court of Common Pleas, Domestic Relations Division. For the reasons that follow, this Court affirms in part and reverses in part.

I.

Relevant Background Information

{¶2} Mr. Lowman and Defendant-Appellee Kathleen A Nelligan were married on October 15, 1988. After a legal separation, Mr. Lowman filed a complaint for divorce and the marriage was terminated by a decree of divorce on November 9, 2021. The decree incorporated the parties’ separation agreement which had been entered into by the parties in 2016, in connection with their legal separation. In the divorce decree, Mr. Lowman was ordered to pay Ms. Nelligan $6,250.00 per month in spousal support and the trial court expressly reserved jurisdiction over the duration, termination, and amount of spousal support pursuant to the parties’ separation agreement.

The separation agreement also provided, “[Mr. Lowman’s] retirement shall constitute a change of circumstances” for purposes of modifying or terminating spousal support.

{¶3} On December 28, 2021, Mr. Lowman moved to modify or terminate his spousal support obligation on the basis of his retirement. That same month, Mr. Lowman also stopped paying his spousal support obligation to Ms. Nelligan. On November 17, 2022, a hearing on Mr. Lowman’s motion was held before a magistrate. The facts are largely undisputed. Ms. Nelligan suffers from a traumatic brain injury. Her medical condition, expenses, assets, and liabilities had remained the same since the decree of divorce was entered. Mr. Lowman’s circumstances, however, had changed. Specifically, his income was substantially less than when he had signed the separation agreement in 2016. The separation agreement, which set forth Mr. Lowman’s $6,250.00 spousal support obligation, was incorporated into the 2021 divorce decree.

{¶4} In a July 5, 2023 magistrate’s decision, the magistrate terminated Mr. Lowman’s spousal support obligation. Ms. Nelligan filed objections to the magistrate’s decision. The trial court sustained Ms. Nelligan’s objection concerning the termination of spousal support, finding that a modification of spousal support rather than termination was appropriate. The trial court then modified Mr. Lowman’s monthly spousal support obligation from $6,250.00 to $2,000.00 retroactive to December 28, 2021, the date Mr. Lowman filed his motion to modify or terminate spousal support. In doing so, the trial court took into consideration that Mr. Lowman’s income was still substantially higher than Ms. Nelligan’s, that Mr. Lowman receives monthly social security, pension, and annuity payments totaling $4,721.00, and Ms. Nelligan receives a pension in the amount of $592.00 per month. The trial court also took into consideration Mr. Lowman’s substantially reduced income, from over $150,000.00 per year when spousal support was originally calculated, to $56,652.00 per year. The trial court also stated that Ms. Nelligan suffered from a

traumatic brain injury that prevents her from being employed. The record also shows that Ms. Nelligan is unable to work as a result of her brain injury and historically did not work outside of the home during the marriage. Citing the substantial difference that still exists between the parties’ incomes, the trial court found spousal support was still appropriate, especially given the length of the parties’ marriage. The trial court further stated, “[t]he [c]ourt shall retain jurisdiction to modify the amount of spousal support but NOT the duration of spousal support[,]” and [s]pousal support shall terminate upon the death of either party or the remarriage of [Ms. Nelligan].” (Emphasis in original).

{¶5} Mr. Lowman has appealed, raising four assignments of error for our review. We have grouped some assignments of error to facilitate our analysis.

II.

ASSIGNMENT OF ERROR I

THE TRIAL COURT ABUSED ITS DISCRETION AND ERRED BY SUSTAINING [MS. NELLIGAN’S] OBJECTION AND MODIFYING, RATHER THAN TERMINATING, SPOUSAL SUPPORT, DESPITE FINDING NO ERROR OF LAW IN THE MAGISTRATE’S DECISION, ACKNOWLEDGING THE MAGISTRATE’S JURISDICTION, AND RECOGNIZING THE PARTIES’ STIPULATED CHANGE OF CIRCUMSTANCES.

ASSIGNMENT OF ERROR III

THE TRIAL COURT ABUSED ITS DISCRETION AND ACTED CONTRARY TO R.C. 3105.18 AND CIV.R. 53(D)(4)(d) BY SUSTAINING [MS. NELLIGAN’S] OBJECTION AND MODIFYING, RATHER THAN TERMINATING, SPOUSAL SUPPORT WITHOUT COMPETENT EVIDENCE OR PROPER CONSIDERATION OF THE PARTIES’ ASSETS AND [MS. NELLIGAN’S] NEED.

{¶6} In his first and third assignments of error, Mr. Lowman argues the trial court abused its discretion by sustaining Ms. Nelligan’s objection to the magistrate’s decision when it modified rather than terminated his spousal support obligation. “This Court reviews a trial court’s action

with respect to a magistrate’s decision for an abuse of discretion. In so doing, we consider the trial court’s action with reference to the nature of the underlying matter.” (Internal citations omitted.) Foster v. Foster, 2010-Ohio-4655, ¶ 6 (9th Dist.). An abuse of discretion means more than an error of judgment; it implies that the trial court’s attitude was arbitrary, unconscionable, or unreasonable. Blakemore v. Blakemore, 5 Ohio St.3d 217, 219 (1983). Moreover, it is well settled that the trial court is vested with broad discretion over matters of spousal support. Poitinger v. Poitinger, 2005-Ohio-2680, ¶ 7 (9th Dist.). “This Court reviews a trial court's award of spousal support under an abuse of discretion standard.” Doubler v. Doubler, 2023-Ohio-393, ¶ 14 (9th Dist.).

{¶7} The material facts here do not appear to be in dispute. The parties agreed that Mr.

Lowman’s retirement would constitute a change of circumstances for purposes of modifying spousal support. Section 5.03 of the separation agreement provides:

[s]aid spousal support obligation shall be modifiable and the [c]ourt shall retain jurisdiction over the issue of spousal support (duration, termination, and amount).

Husband’s retirement shall constitute a change of circumstances.

(Emphasis in original). R.C. 3105.18(E) provides in relevant part:

if a continuing order for periodic payments of money as spousal support is entered in a divorce or dissolution of marriage action that is determined on or after January 1, 1991, the court that enters the decree of divorce or dissolution of marriage does not have jurisdiction to modify the amount or terms of the alimony or spousal support unless the court determines that the circumstances of either party have changed and unless one of the following applies:

(1) In the case of a divorce, the decree or a separation agreement of the parties to the divorce that is incorporated into the decree contains a provision specifically authorizing the court to modify the amount or terms of alimony or spousal support.

{¶8} Mr. Lowman’s income has changed, but Ms. Nelligan’s physical condition, income, assets, and debts have remained the same since the date of the divorce decree. The parties did not agree in their separation agreement that Mr. Lowman’s spousal support obligation would

terminate upon his retirement. They agreed that his retirement constituted a change of circumstances, which allowed the trial court to consider whether terminating or modifying spousal support was appropriate and reasonable, and to determine the nature, amount, terms of payment, and duration of spousal support. See R.C. 3105.18(C)(1).

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