Background
D.C. and J.W., who were never married, share two children. In November 2025, a juvenile-court magistrate granted their agreed shared-parenting plan and set a child-support hearing, directing the parties to bring financial records and directing the Office of Child Support Services (OCSS) to submit any administrative orders.
OCSS submitted an order requiring Father to pay Mother $617.17 per month in child support and $69.90 per month in cash medical support. At the subsequent hearing, neither parent introduced financial evidence, neither had filed a motion to modify support, and Mother asked that the existing order remain in place. The magistrate adopted the administrative order, and the juvenile court later reissued its adoption order. Father appealed without first objecting to the magistrate’s decision.
The Court’s Holding
The Eighth District affirmed. Because Father did not object to the magistrate’s decision in juvenile court, appellate review was limited to plain error. The court found none: the administrative order was the only financial information before the court after the parties failed to present the requested documentation, and Father identified nothing showing that the OCSS order failed to support maintaining the existing support obligation.
The court also held that Father had not placed a support modification before the juvenile court. Although a shared-parenting order triggers a child-support evaluation, Father neither filed a court motion to modify under R.C. 3119.79 nor sought an administrative review through OCSS. With no modification request or resulting ruling below, the appellate court would not consider Father’s arguments about recalculation, deviation, parenting time, or unemployment for the first time on appeal.
Key Takeaways
- A party who does not object to a juvenile magistrate’s decision generally receives only plain-error review on appeal.
- Parents bear the burden of providing documents verifying income for child-support calculations.
- A challenge seeking modification of an existing support order must first be raised through a proper court motion or administrative-review request.
Why It Matters
The decision underscores that shared parenting does not itself permit an appellate court to recalculate child support on an undeveloped record. Litigants seeking a different obligation must present financial evidence and use the available modification procedures in the juvenile court or through OCSS.