The Ohio Court of Appeals has upheld a lower court's decision to grant spousal support to Sheila Leyes, n.k.a. Sheila Elkins, in her divorce from Gary Leyes. The ruling, issued on June 1, 2026, affects both parties, particularly Sheila, who has significant health issues and no current income. This case highlights the complexities of spousal support determinations in divorce proceedings.
The case, Leyes v. Leyes, was filed under docket number CA2025-07-033. Sheila filed for divorce in August 2023 after nearly 17 years of marriage. The couple has no children, and the divorce proceedings focused primarily on the financial aspects of their separation, particularly the amount and duration of spousal support.
The parties had a modest lifestyle during their marriage, with Sheila primarily serving as a homemaker since 2008 after working minimum wage jobs for the first two years. Gary, on the other hand, was the primary wage earner, working as a skilled heavy equipment mechanic. He earned $42 an hour and frequently worked overtime, significantly increasing his income. Sheila suffers from multiple serious health conditions, including chronic obstructive pulmonary disease (COPD), emphysema, and PTSD, which prevent her from being self-supporting.
The dispute over spousal support arose during an evidentiary hearing in December 2024, where both parties testified about their financial situations. The magistrate recommended that Gary pay Sheila a lump-sum spousal support of $18,000, along with monthly payments of $2,400 for an indefinite period. The recommendation was based on the significant disparity in their incomes and Sheila's inability to work due to her health issues.
On June 26, 2025, the trial court modified the magistrate's recommendation, limiting the duration of spousal support to 120 months but maintaining the monthly payment amount. Gary Leyes appealed this decision, arguing that the trial court erred in several aspects of the spousal support award.
The Ohio Court of Appeals, led by Judge M. Powell, ruled that the trial court did not abuse its discretion in awarding spousal support. The court stated, "A trial court has broad discretion in determining whether to award spousal support, as well as the amount and duration of such award, based on the facts and circumstances of each case." The court emphasized that the trial court had considered all relevant factors in determining the spousal support award.
Gary raised several challenges to the trial court's decision, including the lump-sum payment, the inclusion of overtime in calculating his income, the tax rate applied, and the determination that Sheila could not be self-supporting. The court found that Gary had waived his right to appeal the lump-sum payment by failing to object to it during the lower court proceedings.
Regarding the inclusion of overtime in his income calculation, the court ruled that it was appropriate to consider all sources of income, including overtime, as Gary had regularly earned it. The court also upheld the trial court's assumption of a 20 percent tax rate, stating that it was reasonable given the lack of evidence to the contrary.
Finally, the court supported the trial court's conclusion that Sheila could not be self-supporting due to her severe health issues. The court noted that expert medical testimony was not required to establish her inability to work, as her testimony was sufficient.
The ruling has significant implications for both parties. Sheila Leyes will continue to receive financial support, which is crucial given her health challenges and lack of income. For Gary Leyes, the ruling affirms his obligation to provide support for a decade, impacting his financial planning and future earnings.
This case sets a precedent for how courts may approach spousal support in situations where one party has significant health issues and the other has a stable income. It underscores the importance of considering the totality of circumstances in divorce cases, particularly regarding the earning abilities and health conditions of both parties.
Looking ahead, it is unclear whether Gary Leyes will seek further legal action or appeal to a higher court. The court's decision is final unless new evidence arises or a significant change in circumstances occurs. As it stands, the ruling reinforces the trial court's authority to determine spousal support based on the unique facts of each case.