The Ohio Court of Appeals recently issued a ruling in the child support case of In re K.L.D. (No. 115816), affecting the financial obligations of a father, D.D., towards his minor child. The court's decision, released on June 18, 2026, addressed several critical issues, including service of process and the imputation of income for child support calculations.
The case began when D.D. filed an application to determine custody of his child, K.L.D., born on April 27, 2008. The child's mother, J.C., waived service of the application, and both parents participated in mediation, resulting in an agreement that designated J.C. as the residential parent for school purposes. However, as the case progressed, the juvenile court failed to issue a child support order following its custody ruling.
In May 2025, the Office of Child Support Services (OCSS) intervened, moving to establish child support obligations for D.D. The OCSS specified a new address for D.D., which had not been previously used in the case. This change in address became a point of contention as D.D. claimed he did not receive proper notice of the proceedings.
The juvenile court held hearings on the child support matter, ultimately finding that D.D.'s employment status was unknown. The court decided to impute income to him based on the average salary of a plumber, despite D.D. being a plumbing apprentice. This decision led to D.D. appealing the court's ruling, arguing that it violated his due process rights and that the income imputation was improper.
Background
The dispute arose after D.D. initiated custody proceedings in November 2023. Throughout the case, D.D. consistently listed his address as 4233 W. 23rd St., Cleveland, OH. However, OCSS later filed documents using a different address, 10937 Pasadena Ave., Cleveland, OH, to serve D.D. This discrepancy raised questions about whether D.D. received proper notice of the hearings and the final child support order.
In the hearings leading up to the court's decision, D.D. did not object to the magistrate's findings or the service of process. The magistrate ultimately found that D.D. had an imputed income of $62,970 based on the average earnings of a plumber, despite evidence suggesting he was only an apprentice. The court ordered D.D. to pay $670.89 per month in child support, plus additional medical support.
The Ruling
The Ohio Court of Appeals reviewed the case and found merit in D.D.'s appeal, particularly regarding the imputation of income. The court stated, "The juvenile court's error requires a new evidentiary hearing as to father's income and employment and therefore revised worksheet calculations as to his support obligations." The ruling emphasized that the juvenile court must determine whether D.D. was voluntarily unemployed or underemployed before imputing income.
Judge Deena R. Calabrese, who authored the opinion, noted that the juvenile court did not make necessary findings regarding D.D.'s employment status. The court ruled that the case should be remanded for further proceedings to ensure that accurate income information is obtained and that child support obligations are calculated correctly.
Impact
This ruling has significant implications for D.D. and other parents in similar situations. It underscores the importance of proper service of process in child support cases and the need for courts to adhere to statutory requirements when determining income for support calculations. The decision also highlights the necessity for courts to provide clear findings regarding a parent's employment status before making determinations about child support obligations.
Going forward, the case sets a precedent for how courts in Ohio handle child support calculations, particularly in cases where a parent's employment status is unclear. The ruling reinforces the principle that courts must follow legal standards closely to ensure fairness in child support determinations.
What's Next
The case has been remanded to the juvenile court for a new hearing regarding D.D.'s income and employment status. This will allow for a more accurate assessment of his child support obligations. There is no indication in the court filing that the case can be further appealed at this time, but D.D. may have the opportunity to present additional evidence regarding his employment and income during the upcoming proceedings.