Greer v. Greer, 2019 Ohio 4304

Parties divorced in 1984. Decree awarded Pamela the marital residence and ordered her to pay Edward $6,355 (to compensate his share of equity) at $100/month via the Bureau of Support; no spousal support awarded.
Wage withholding orders were in place; a November 1989 trial-court entry stated the “support order” was paid and terminated Pamela’s wage assignment.
In 2016 Edward filed a motion to show cause (contempt), alleging Pamela had not paid the $6,355; he later voluntarily dismissed the motion in 2017 after learning he had been paid.
Pamela moved for attorney fees under R.C. 3105.73(B) for fees incurred defending the 2016 contempt motion; a magistrate awarded $1,090 and the trial court adopted that decision.
Edward objected; the trial court overruled the objections and entered judgment awarding Pamela $1,090 in fees. Edward appealed.
The Ninth District affirmed: the court found the trial court did not abuse its discretion in awarding fees, relying on the parties’ conduct, incomes, and the trial court’s determination that the hourly rate and time were reasonable without expert testimony.

Issue	Plaintiff's Argument (Greer)	Defendant's Argument (Greer)	Held
Whether R.C. 3105.73(B) fee award was equitable	Award was not warranted by his conduct; Pamela was not in need; fees unreasonable and unsupported	Pamela incurred fees because Edward filed a baseless contempt motion 30 years after decree	Affirmed: trial court did not abuse discretion — fee award was equitable based on conduct and incomes
Whether trial court abused discretion in overruling objections to magistrate	Magistrate’s finding and award were unreasonable	Magistrate correctly found Pamela had paid the decree amount and incurred fees due to Edward’s action	Affirmed: objections properly overruled; magistrate’s factual findings supported
Whether Pamela had to prove fee reasonableness via expert testimony	Expert testimony was required to prove reasonableness of hourly rate/time	Expert testimony not required; trial court can rely on its knowledge and record	Affirmed: expert testimony not required; trial court reasonably found $200/hr and time charged fair and reasonable

None of the authorities cited in the opinion have official reporter (Bluebook) citations. The opinion primarily cites Ohio appellate slip opinions and local-rule authorities, but no cases with official reporter citations are available to list.