McCormick v. McCormick, 2022 Ohio 3543

Lydia (Wife) and Joshua (Husband) McCormick divorced in 2016; the decree awarded Husband the dependent tax exemptions for the two minor children and required Husband (a California resident) to “pay the cost of transporting the children to and from parenting time.”
In March 2021 Wife moved to recover $2,614.40 in incidental transport costs (mileage, parking, and value of her time) that she incurred delivering the children to the airport; Husband had paid the children’s airfare.
Wife also sought judgment for COVID‑19 stimulus payments Husband received for the children (2020–2021) and asked that future stimulus payments be directed to her as the residential parent.
A magistrate denied Wife’s requests, reasoning the divorce decree accounted for transportation costs in Husband’s spousal‑support calculation and that, because Husband received the dependency exemptions, he was entitled to the stimulus funds under federal law.
The trial court adopted the magistrate’s decision; Wife appealed. The Court of Appeals affirmed the denial of transportation reimbursement (finding the decree ambiguous and the trial court’s interpretation not an abuse of discretion) but reversed in part and remanded on the stimulus‑payment issue for a threshold statutory qualification determination.

Issue	Wife's Argument	Husband's Argument	Held
Who is entitled to past and future COVID stimulus payments for 2020–2021?	The payments should be awarded to Wife (residential parent); trial court should require Husband to turn over past stimulus money and direct future payments to Wife.	The decree awards Husband the children’s dependency exemptions; under federal statute the parent who qualifies or claims the children is entitled to the stimulus payments.	Court: Trial court properly considered federal statutes but failed to decide the threshold question whether the children were qualifying children of Husband under the federal tax code; remanded for that determination (Wife’s assignment sustained in part).
Whether Husband must reimburse Wife for incidental transportation costs (mileage, parking, value of time) delivering children to/from airport	“Pay the cost of transporting” includes incidental expenses Wife incurred beyond airfare; decree unambiguous in her favor.	“Pay the cost” was reasonably read to mean airfare (transportation of the children), not incidental expenses.	Court: Decree language is ambiguous as to what "cost" means; trial court did not abuse its discretion in treating it as ambiguous and resolving the dispute—Wife failed to separately argue the trial court’s chosen interpretation was erroneous; assignment overruled.

Quisenberry v. Quisenberry, 91 Ohio App.3d 341 (1993) (trial court may clarify and resolve genuine confusion over interpretation of a divorce decree)
Boulger v. Evans, 54 Ohio St.2d 371 (1978) (defining contractual ambiguity as admitting two or more meanings)