Weaver v. Weaver, 2017 Ohio 4087

Jonathan and April Weaver divorced in 2010 and adopted a shared parenting plan for their two children.
The plan gave Jonathan regular weekday and alternating weekend/overnight parenting time, with a right of first refusal if the custodial parent was away more than six hours.
In 2014 April sought modification of the parenting plan; Jonathan sought (among other relief) either elimination of child support or a downward deviation due to increased parenting time.
A magistrate kept Jonathan on guideline child support but limited the right of first refusal; the trial court modified parenting time to add an extra overnight for Jonathan and affirmed the guideline child support obligation.
Jonathan appealed solely arguing the court abused its discretion by refusing a downward deviation from guideline child support.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused its discretion by refusing to deviate downward from the guideline child support amount	Jonathan: His extended/alternate parenting time and comparable incomes justify a downward deviation	April: Guideline amount is presumptively correct; no abuse of discretion shown to deviate	Court: No abuse of discretion; trial court properly declined to deviate and relied on record evidence

Pauly v. Pauly, 80 Ohio St.3d 386 (Ohio 1997) (trial court child-support determinations reviewed for abuse of discretion)
Blakemore v. Blakemore, 5 Ohio St.3d 217 (Ohio 1983) (definition of abuse of discretion)
Ross v. Ross, 64 Ohio St.2d 203 (Ohio 1980) (some competent, credible evidence supports trial court decision)