Manos v. Manos, 2012 Ohio 2281

Tammy J. Manos appeals a June 8, 2011 divorce judgment in Summit County, remanded from a prior decision for unresolved spousal-support duration and arrearage issues.
Original 2008 divorce judgment awarded Wife $1,500/month spousal support for 72 months, with nine-year intent from start of temporary support; Husband paid for nearly two years.
On remand, the trial court reissued the judgment with nine-year and 84-month terms appearing, and found an arrearage for utilities, medical expenses, condo fees, and auto repairs, while stating spousal support was current.
Appellate remand mandated clarification of spousal-support duration and the amount of temporary-support arrearage; the June 2011 judgment did not resolve these consistently.
The court on remand ordered correction to run spousal support through June 30, 2016 (or until remarry/die) and to determine the correct temporary-spousal-support arrearage, prompting Wife’s current appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Clarify spousal support duration and incorporation	Manos argues the terms are inconsistent and not incorporated	Manos argues no agreement existed; the court corrected, but ambiguity remains	Inconsistent terms persist; mandate requires correction to run to 6/30/2016
Proper amount of temporary-spousal-support arrearage	Wife asserts a specific arrearage amount based on temporary support	Husband contends different figures; checks allegedly show payments	Remand to determine the correct arrearage amount and reflect in the judgment
Compliance with appellate mandate on remand			Court must implement corrective changes on remand; judgment revised to reflect clarified terms

Graham v. Graham, 98 Ohio App.3d 396 (2d Dist.1994) (trial court must follow appellate mandate; cannot extend or vary it)
Nolan v. Nolan, 11 Ohio St.3d 1 (1984) (mandate cannot be expanded or varied by trial court)