Lawrence v. McCraw, 2011 Ohio 6334

Unmarried parents Katie Lawrence and Dennis McCraw are biological parents of one child.
McCraw historically paid child support under an order that was canceled when they briefly lived together.
Lawrence filed May 2009 seeking establishment or modification of child support.
Magistrate ordered $300.58 monthly child support and a 2% processing charge based on a 2006 worksheet not signed by either party.
Record showed most proceedings occurred off the record; the 2006 worksheet may not reflect current income.
Trial court overruled objections and awarded the dependency tax exemption to McCraw in alternating years without current financial data; Lawrence appeals.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether child support was properly calculated.	Lawrence argues no current worksheet or appropriate current-income data.	McCraw does not oppose record-based calculation; the parties agreed to the amount.	Partially sustained; remand for completion of current worksheet and proper calculation.
Whether the dependency tax exemption was properly awarded.	Lawrence contends there is no record support for alternating-year exemption.	McCraw contends award follows statutory factors and record supports it.	Errored; remand for financial data supporting exemption decision.

DePalmo v. DePalmo, 78 Ohio St.3d 535 (Ohio 1997) (mandatory application of child support guidelines; deviation requires fact finding and journaled findings)
Marker v. Grimm, 65 Ohio St.3d 139 (Ohio 1992) (child support worksheet must be completed and part of the record; guidelines are presumptively correct)
Cameron v. Cameron, 2005-Ohio-2435 (Ohio 2005) (541? (application of 3119.02/3119.22 standards; worksheet requirement))
Ankney v. Bonos, 2006-Ohio-6009 (Ohio 2006) (allocation of tax exemptions requires financial data in the record)
Day v. Bloom, 2006-Ohio-6957 (Ohio 2006) (courts must consider child’s best interests and proper financial data for deviation)