Bohme v. Bohme, 2017 Ohio 1190

Michelle Hanley and Richard Bohme divorced after a 20+ year marriage; decree (Nov. 2013) ordered Bohme to pay $9,000/month spousal support for seven years and $956/month child support. One child remained a minor.
Bohme moved to modify support in April 2014 alleging decreased income from his dental practice; parties entered an agreed order in Jan. 2015 allowing a temporary reduced spousal payment while accrual continued and permitting retroactive modification to the April 14, 2014 filing date after appeal resolution.
Bohme filed a motion to reduce spousal and child support in March 2015; Hanley filed contempt for unpaid support. A magistrate reduced spousal support to $7,000/month (effective May 1, 2014) and child support to $930/month (effective April 1, 2015), found Bohme in contempt, and ordered $200/month toward the spousal arrearage plus $350 attorney fees.
Hanley objected to the magistrate’s findings, contesting the income reduction finding and the low $200/month arrearage repayment rate; the trial court sustained the income reduction but increased arrearage repayments to $1,500/month (with a large post-term catch-up provision).
Trial court found Bohme’s dental-practice income fell substantially (from the $500,000 assumed at divorce to roughly $369,040 in 2014), relied on uncontroverted accountant testimony, noted discretionary purchases but accepted Bohme’s explanations, and concluded the support reductions were not an abuse of discretion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Bohme’s income decreased sufficiently to warrant reducing spousal support	Hanley: No — income not sufficiently reduced; magistrate erred	Bohme: Yes — dental practice income declined substantially since decree	Court: Yes — found >22% reduction vs. amount used at divorce; reduction to $7,000/month appropriate and effective May 1, 2014
Whether child support should be reduced	Hanley: Child support should not be reduced absent substantial, uncontested change	Bohme: Combined income changed and child-support recalculation under high-income rules justifies modest reduction	Court: Yes — reduced child support from $956 to $930/month effective April 1, 2015; treated needs/standard-of-living and substantial-change policy considerations as relevant
Whether the magistrate’s $200/month arrearage repayment rate was adequate	Hanley: $200/month is unreasonably low (would take decades to repay)	Bohme: Could only afford low payment given cash flow/expenses	Court: Rejected $200; ordered $1,500/month until arrearage satisfied and a high catch-up rate if balance remained after support term
Whether trial court abused discretion in its overall determinations	Hanley: Trial court abused discretion by accepting Bohme’s income figures and allowing reduction	Bohme: Trial court acted within discretion based on uncontradicted financial evidence	Court: No abuse of discretion; verdict affirmed

Blakemore v. Blakemore, 5 Ohio St.3d 217 (1983) (abuse-of-discretion standard for appellate review of trial-court determinations)
Tremaine v. Tremaine, 111 Ohio App.3d 703 (2d Dist. 1996) (change of circumstances must be substantial and not contemplated at time of prior order)
Reveal v. Reveal, 154 Ohio App.3d 758 (2d Dist. 2003) (party seeking reduction of spousal support bears the burden of proof)