The Ohio Court of Appeals has upheld a lower court's decision regarding spousal support in the case of Ward v. Grounds, C.A. No. 2025-CA-61. The court ruled that Robert Grounds must continue to pay spousal support to his ex-wife, Marilyn Ward, despite his claims that she was cohabitating with another man. This ruling affects divorced couples navigating spousal support obligations, particularly in cases involving cohabitation.
The case began when Robert Grounds filed a motion to terminate or modify his spousal support payments, claiming that Marilyn Ward was living with a man named John Frost. Grounds argued that this cohabitation should eliminate or reduce his financial obligation. However, the trial court found that Ward and Frost's living arrangement did not constitute cohabitation as defined in their divorce decree.
Marilyn Ward and Robert Grounds were married for over twenty years before their divorce in December 2021. The divorce decree mandated that Grounds pay Ward $2,400 per month in spousal support for 84 months, with the condition that the support would cease if Ward cohabitated with an unrelated adult. Grounds alleged that Ward began living with Frost in April 2025, prompting him to seek a modification of his support payments.
The trial court held an evidentiary hearing where both Grounds and Ward testified. The court found that while Ward did live with Frost, she did not cohabitate with him in a way that would terminate her spousal support. The trial court noted that Ward had initially paid rent but later reduced her housing costs by providing household services instead. The court determined that there was no evidence of a romantic relationship or shared financial responsibilities between Ward and Frost.
Judge Michael L. Tucker, along with judges Lewis and Hanseman, concurred with the ruling. The court stated, "The absence of [a] financial assumption/marital type relationship prevents a finding of cohabitation for the purposes of spousal support termination." The court also found no abuse of discretion in the trial court's decision to maintain the spousal support amount, citing Ward's limited income and ongoing health issues as factors in their decision.
The ruling has significant implications for future cases involving spousal support and cohabitation. It clarifies that merely living with someone does not automatically equate to cohabitation under the law if there is no financial interdependence or romantic relationship. This decision may influence how courts interpret cohabitation in future spousal support cases.
Grounds may consider appealing the decision, but the court filing did not indicate any related cases pending. The ruling emphasizes the importance of financial independence and the specific definitions of cohabitation within divorce decrees.