In re P.J.H., 962 N.E.2d 389

P.J.H. is the child of Kenney (residential parent) and Hale; Miami County Juvenile court case; Kenney filed April 30, 2010 motion for child support after Hale initially provided daycare in lieu of support; trial court ordered Hale to pay child support beginning August 20, 2010, not April 30, 2010; July 5, 2011 journal entry designated August 20, 2010 as the effective date; Hale argued December 10, 2010 as a better date due to later agreements; Kenney appealed timely on July 26, 2011; case is an appeal from a domestic relations order concerning the effective date of child support.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused its discretion in setting the effective date for Hale’s child support.	Kenney argues August 20, 2010 is improper; April 30, 2010 is the date of the motion.	Hale contends special circumstances justify a later date (December 10, 2010) to avoid double payment.	The court sustained the assignment of error; the date was reversed and remanded for a proper date.

Booth v. Booth, 44 Ohio St.3d 142 (1989) (abuse-of-discretion standard for child-support orders)
Huffman v. Hair Surgeon, Inc., 19 Ohio St.3d 83 (1985) (abuse-of-discretion framework)
AAAA Ents., Inc. v. River Place Community Redevelopment, 50 Ohio St.3d 157 (1990) (sound reasoning required for discretionary decisions)
Murphy v. Murphy, 13 Ohio App.3d 388 (1984) (modification effective date generally retroactive to motion date)
State ex rel. Draiss v. Draiss, 70 Ohio App.3d 418 (1990) (modification dates should reflect significant events in litigation)
Ebersole v. Ebersole, 2009-Ohio-6581 (Montgomery App.) (significance of dates in modification filings)
Quint v. Lomakoski, 173 Ohio App.3d 146 (2007-Ohio-4722) (modification orders may be retroactive to filing date absent special circumstances)
Bell v. Bell, 2010-Ohio-5276 (Montgomery App.) (significance required for choosing dates in litigation)