Ritzinger v. Ritzinger

2012 Ohio 5052
CourtOhio Court of Appeals
DecidedOctober 31, 2012
Docket26328
StatusPublished
Cited by1 cases

This text of 2012 Ohio 5052 (Ritzinger v. Ritzinger) 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
Ritzinger v. Ritzinger, 2012 Ohio 5052 (Ohio Ct. App. 2012).

Opinion

[Cite as Ritzinger v. Ritzinger, 2012-Ohio-5052.]

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

DEBORAH RITZINGER C.A. No. 26328

Appellee

v. APPEAL FROM JUDGMENT ENTERED IN THE GREGORY RITZINGER COURT OF COMMON PLEAS COUNTY OF SUMMIT, OHIO Appellant CASE No. 2005-08-2904

DECISION AND JOURNAL ENTRY

Dated: October 31, 2012

DICKINSON, Judge.

INTRODUCTION

{¶1} When Gregory and Deborah Ritzinger divorced, the court ordered Mr. Ritzinger

to pay child and spousal support. After Ms. Ritzinger began living with another man, Mr.

Ritzinger moved the trial court to decrease or terminate his spousal support obligation. Ms.

Ritzinger then moved for an increase in spousal and child support. Following an evidentiary

hearing, a magistrate ordered the spousal support obligation to remain the same, but increased

child support. In ruling on Mr. Ritzinger’s objections, the trial court denied the requested

changes in spousal support and denied the requested increase in the amount of child support. Mr.

Ritzinger appealed. This Court affirms because the trial court properly exercised discretion in

weighing the parties’ increased income disparity more heavily than the contribution to living

expenses that Ms. Ritzinger receives from her boyfriend, by considering the parties’ income at

the time of the hearing as opposed to the date of the initial motion to modify spousal support, and 2

by modifying the parties’ obligations regarding uninsured medical expenses for the minor child

without increasing the monthly child support obligation. Further, the trial court undertook an

independent review of the matters to which Mr. Ritzinger had objected and, assuming without

deciding that the trial court’s determination regarding a substantial change in circumstances was

wrong, it was harmless error.

BACKGROUND

{¶2} After nearly 25 years of marriage and three children together, the Ritzingers

divorced in June 2007. At that time, the trial court adopted a proposed shared parenting plan

designating Ms. Ritzinger’s residence as the primary residence of the two minor children for

school purposes. It also projected Ms. Ritzinger’s income to be just over $36,500 per year while

it projected Mr. Ritzinger’s income to be $108,000. Mr. Ritzinger was ordered to pay child

support and spousal support. The trial court provided that spousal support would terminate if

Ms. Ritzinger remarried or if either party died. The order did not include a provision that

spousal support would terminate if Ms. Ritzinger cohabitated with another person. The court

reserved jurisdiction to modify spousal support.

{¶3} In August 2009, Mr. Ritzinger moved the trial court to terminate or modify

spousal support based on a change in circumstances. Mr. Ritzinger argued that, because Ms.

Ritzinger had begun to share household expenses with a live-in boyfriend, the spousal support

order should be decreased or terminated. Ms. Ritzinger opposed the motion and moved for an

increase in both child and spousal support. A magistrate held evidentiary hearings in March,

May, and June 2010 before filing a decision on July 1, 2010. The magistrate denied the motions

to modify spousal support, but recommended an increase in child support. Mr. Ritzinger filed

objections to the magistrate’s decision. The trial court entered judgment on those objections on 3

February 14, 2012. It determined that a substantial increase in Mr. Ritzinger’s income created a

substantial change in circumstances, but further determined that, because Ms. Ritzinger and

Brian Yelling had already formed a domestic partnership at the time the divorce was granted, her

cohabitation with him was not a substantial change in circumstances. The trial court ordered no

change in spousal support or the monthly obligation for child support, but awarded Mr. Ritzinger

the tax exemption for the only remaining minor child and ordered him to pay 70% of the child’s

uninsured medical expenses.

CHANGE IN CIRCUMSTANCES

{¶4} Mr. Ritzinger’s second and third assignments of error are that the trial court

incorrectly determined that there was no change in circumstances because Ms. Ritzinger had

established a domestic partnership with Mr. Yelling by the time the divorce decree was issued.

Although the trial court found a significant change in circumstances based on other evidence,

Mr. Ritzinger has argued that the trial court incorrectly determined that Ms. Ritzinger’s

cohabitation with Mr. Yelling was not a substantial change in circumstances not contemplated at

the time of the divorce.

{¶5} Modification of spousal support “requires a two-step analysis[.]” Tufts v. Tufts,

9th Dist. No. 24871, 2010-Ohio-641, ¶ 8 (citing Malizia v. Malizia, 9th Dist. No. 22565, 2005-

Ohio-5186, ¶ 8). “The first step is jurisdictional and requires the trial court to determine whether

the original divorce decree provided continuing jurisdiction to modify the spousal support award,

and if so, whether the circumstances of either party have changed.” Id. (citing Malizia, 2005-

Ohio-5186, at ¶ 8; R.C. 3105.18(E)). “[T]he Ohio Supreme Court has clarified that ‘[a] trial

court lacks jurisdiction to modify a prior order of spousal support unless the decree of the court

expressly reserved jurisdiction to make the modification and unless the court finds (1) that a 4

substantial change in circumstances has occurred and (2) that the change was not contemplated

at the time of the original decree.’” Id. (quoting Mandelbaum v. Mandelbaum, 121 Ohio St. 3d

433, 2009-Ohio-1222, paragraph two of the syllabus). Once jurisdiction is established, the

second step of the analysis requires the trial court to consider the factors set forth in Section

3105.18(C)(1) of the Ohio Revised Code to determine whether the existing support order should

be modified in light of the change in circumstances. Id.

{¶6} In this case, the trial court determined that it had jurisdiction to consider a

modification of the spousal support order because there was “at least one substantial change of

circumstance not contemplated at the time of the divorce[.]” That is, the trial court determined

that Mr. Ritzinger’s annual income had increased by almost $20,000. The court also determined

that Ms. Ritzinger’s income had decreased by the same amount “[o]ver the pendency of the

motions to modify[.]” The court determined that Ms. Ritzinger’s cohabitation with Mr. Yelling

did not constitute a substantial change in circumstances not contemplated at the time of the

divorce because Ms. Ritzinger had already established a “domestic partnership” with Mr. Yelling

by the time the trial court issued the divorce decree.

{¶7} Mr. Ritzinger has not argued that the trial court incorrectly determined that it had

jurisdiction to modify spousal support. Nor has he argued that the trial court incorrectly found

an increase of $40,000 in the income disparity between the parties or that the trial court

incorrectly found that the increased disparity was a substantial change not contemplated at the

time of the divorce. His argument is that the trial court should have determined that Ms.

Ritzinger’s cohabitation with Mr. Yelling was a change in circumstances. Assuming that the

trial court incorrectly determined that Ms. Ritzinger’s cohabitation was not a substantial change

in circumstances not contemplated at the time of the divorce, Mr.

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