Walker v. Hughes, 2017 Ohio 9029

James A. Walker (father/obligor) and Rhyan Hughes (mother/residential parent) share a minor child; CSEA had issued administrative child-support orders naming Walker the obligor.
CSEA's May 10, 2016 worksheet attributed Walker gross income of $31,416.06 (including overtime/bonuses) and adjusted gross of $28,030.66 for support computation.
Walker filed an objection/complaint to set support, asserting inability to pay; a magistrate heard the matter on August 15, 2016 and reduced Walker's gross and adjusted income (worksheet listing $20,737.60 gross, $17,722.85 adjusted), yielding a lower support obligation.
The trial court adopted the magistrate’s decision on August 23, 2016. Hughes (mother) did not file objections to the magistrate’s decision in the trial court but appealed the adoption.
No transcript of the August 15, 2016 hearing was provided on appeal; the court treated Hughes as having waived all but plain-error review and affirmed the trial court’s decision.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred by excluding overtime/bonuses when calculating Walker's gross income for child-support computation	Walker argued actual earnings and expected income supported a lower gross-income figure (no overtime/bonuses included)	Hughes argued overtime/bonuses earned in the prior year or expected in the current year should be included in gross income	Court affirmed: because Hughes failed to file objections and provided no hearing transcript, review limited to plain error; no plain error shown and trial court's adoption stands

Knapp v. Edwards Laboratories, 61 Ohio St.2d 197 (1980) (appellant bears burden to provide transcript to demonstrate trial-court error)
Maloney v. Maloney, 34 Ohio App.3d 9 (1986) (failure to file necessary transcript results in overruling assignments of error)