Lorson v. Lorson, 2017 Ohio 8562

Paul and Debra Lorson married in 2012 and divorced in 2017; most property issues were resolved but spousal support remained contested.
Trial court awarded Debra spousal support of $583 per month for 13 months. The court explained it used one-third of the marriage duration (stated as 40 months) to set the duration.
Paul (Appellant) argued the court abused its discretion: he should receive credit for 11 months of temporary spousal support already paid and the 13‑month duration is excessive given the short marriage.
The appellate record did not include the trial transcript because Paul failed to file a court‑reporter–signed praecipe.
Because the transcript was missing, the Ninth District presumed regularity of the trial court’s proceedings and affirmed the spousal support award.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused its discretion by awarding 13 months of spousal support	Lorson: award is excessive given a 23‑month cohabitation and he already paid 11 months of temporary support	Trial court: considered evidence and full record in setting support (court proceeded to award 13 months)	Affirmed — appellate court cannot review without trial transcript and thus presumes regularity; assignments of error overruled

Blakemore v. Blakemore, 5 Ohio St.3d 217 (1983) (defines abuse of discretion standard)
Knapp v. Edwards Laboratories, 61 Ohio St.2d 197 (1980) (when transcript is missing, appellate court must presume validity of lower court proceedings)
Wozniak v. Wozniak, 90 Ohio App.3d 400 (9th Dist. 1993) (presumption of regularity applies when record is incomplete)