Pearson v. Pearson, 2022 Ohio 642

Tracey L. Pearson filed for divorce from Mark T. Pearson; they had been married ~29 years (married 1991) and the two children were emancipated.
At the final hearing (Nov. 30, 2020) Tracey’s 2020 projected income was about $16,251; Mark’s projected 2020 income (from two jobs) was about $54,009.32. Historical incomes for both parties were also presented.
The magistrate recommended spousal support: $600/month for 60 months, then $500/month for 60 months.
The trial court (Sept. 7, 2021) affirmed the magistrate’s spousal support award, finding it appropriate given incomes, marriage duration, and marital standard of living, and reserved jurisdiction to modify.
Mark appealed, arguing the trial court erred in calculating amount/duration, improperly assumed $54,000 yearly income, failed to explain the award or the step-down after five years, and that the award would render him unable to meet expenses.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused its discretion in awarding spousal support (amount and duration)	Tracey: award appropriate based on incomes, marriage length, and standard of living; trial court considered statutory factors	Mark: award arbitrary and unaffordable; court improperly presumed $54k income and failed to explain amount/duration or why support reduces after five years	Court affirmed: no abuse of discretion; trial court considered R.C. 3105.18 factors, reasonably weighed evidence, need not use income averaging, and retained jurisdiction for modification

Kunkle v. Kunkle, 51 Ohio St.3d 64 (1990) (spousal-support awards reviewed for abuse of discretion)
Kaechele v. Kaechele, 35 Ohio St.3d 93 (1988) (trial court must provide sufficient detail to permit appellate review; no strict mathematical formula)
Schultz v. Schultz, 110 Ohio App.3d 715 (1996) (R.C. 3105.18 controls nature, amount, duration of spousal support)
Bowen v. Bowen, 132 Ohio App.3d 616 (1999) (reiterates abuse-of-discretion standard for spousal support review)