Krone v. Krone, 2011 Ohio 3196

Krone v. Krone, Summit County, married March 13, 1993, two children during marriage.
Wife was a homemaker, attended Kent State, and pursued interior design; did not work outside the home.
Husband was a self-employed commercial real estate broker; income fluctuated over the years.
Multiple hearings culminating in a June 4, 2010 final decree; spousal support of $668,644 total, $6,000 monthly, with modification reserved.
Trial court addressed income, duration/amount of support, life-insurance security for arrearage, and child support; appellate court affirmed in part, vacated in part, remanding for correction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Income calculation for support	Krone alleged incorrect income calculation.	Krone contends income was overstated/loaded with personal expenses.	No abuse; court accepted Wife’s income estimate and averaged three years.
Duration and amount of spousal support	Krone contends duration/amount too high given decline in income.	Wife argues court properly applied factors and income potential.	Not an abuse; court retained modifications and set $6,000/month.
Life insurance to secure arrearage	Krone objects to securing arrears with life insurance.	Securing arrears appropriate when arrearage exists.	Not an abuse; permissible to secure arrearage with life insurance.
Child-support calculation	Krone argues improper income averaging and amount.	Wife supports averaging given income volatility.	Income averaging appropriate; remand to correct monthly child-support amount to $1,041.33 per child.

Karis v. Karis, 2007-Ohio-759 (Ohio 2007) (trial court may order life insurance to secure arrearage in special context)
Coors v. MacEachen, 2010-Ohio-4470 (Ohio 2010) (court may retain jurisdiction to modify spousal support as income evolves)
Gore v. Gore, 2010-Ohio-3906 (Ohio 2010) (income fluctuation supports averaging for support calculation)
Johnson v. Huddle, 2004-Ohio-410 (Ohio 2004) (income averaging permitted when income is unpredictable)