Young v. Young, 2011 Ohio 4489

Divorced parents with a daughter; Ms. Young relocated to Florida with child.
June 28, 2007 agreed judgment entry terminated Mr. Young's child support and shifted travel costs to him, citing companionship obligations.
Mr. Young had limited contact and no companionship since 2007.
In 2009, Ms. Young pursued interstate efforts to reinstate support; Mr. Young moved to modify/establish support and address companionship.
Magistrate recommended resuming support, sharing transportation costs, and no contempt against Ms. Young; trial court adopted; Mr. Young appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did court err in establishing child support without change in circumstances finding	Young argued no change warranted support	Young consented to deviation; but court could set support	Overruled; court did not err in establishing support
Did court properly consider downward deviation grounds	Deviation was justified by prior companionship order	Deviation not proven; guidelines control	Overruled; trial court did not abuse discretion in not deviating
Contempt for mother over missed visitation	Ms. Young failed to provide visitation	No clear proof of contempt; findings inadequate	Forfeited; not reversible on appeal
Contempt for missed summer, holidays, and phone contact	Ms. Young denied father time and calls	Objections not specific; contempt not shown	Overruled; preserved arguments not addressed; plain error absent
Contempt standard and appellate review	Contempt findings should be upheld	Appeal failed to meet Civ.R. 53(D)(3) requirements	Assignments III–V overruled

Flanagan v. Flanagan, 174 Ohio App.3d 77 (Ohio App.3d 2007) (limits on establishing support absent modification issue)
Irish v. Irish, 2010-Ohio-403 (9th Dist. 2010) (deviation factors and presumption under R.C. 3119.23)
Maiorana v. Maiorana, 2008-Ohio-6179 (9th Dist. 2008) (guideline deviation standards and factors)