The Ohio Court of Appeals has reversed a lower court's decision to terminate spousal support for Amatha Farrens, ruling that there was not enough evidence to prove she was cohabitating with her boyfriend, Brian Leaming. This ruling affects both Amatha and her former husband, Corey Farrens, who had sought to end his financial obligations based on the claim of cohabitation. The case highlights the complexities of spousal support agreements and the legal definitions of cohabitation.
The case, Farrens v. Farrens (CA2025-08-021), began when Corey filed for divorce in April 2021. The Fayette County Court of Common Pleas awarded Amatha $20,000 per month in spousal support for 39 months, which was set to end upon her remarriage or cohabitation with another adult. The court's decision to terminate the spousal support arose from a motion filed by Corey in January 2025, claiming that Amatha was cohabitating with Leaming.
Corey and Amatha's divorce proceedings included a hearing in 2023, where the magistrate issued a decision that included the spousal support award. The trial court adopted this decision with modifications in August 2024, explicitly stating that the support would end if Amatha cohabitated with an unrelated adult. Following the divorce decree, Amatha began dating Leaming, who moved into her guest bedroom temporarily in late 2023.
However, the court found that Leaming had moved out by March or April 2024, well before the spousal support order was issued. The couple maintained separate residences and finances, with Leaming only spending one to two nights a week at Amatha's home after August 2024. The court noted that there was no evidence of shared expenses, joint bank accounts, or any financial interdependence that would typically characterize a cohabiting relationship.
On June 24, 2025, the trial court held a hearing where both Amatha and Corey, along with Leaming, testified. The court found that Amatha and Leaming were cohabitating, citing various factors such as shared meals and social activities. However, the Ohio Court of Appeals disagreed, stating that the evidence did not support a finding of cohabitation as defined by law. The court emphasized that cohabitation requires both a sustained living arrangement and financial interdependence, which were absent in this case.
Judge M. Powell, writing for the court, stated, "The credible and undisputed testimony establishes that Amatha and her paramour were in an exclusive dating relationship—one in which they maintained separate residences, paid their own bills, kept their finances independent, and split occasional social expenses in the way dating couples typically do." The court concluded that the trial court's finding of cohabitation was not supported by competent evidence, leading to an abuse of discretion.
The ruling is significant as it clarifies the legal standards for determining cohabitation in the context of spousal support. The court noted that merely living together or having a romantic relationship does not equate to cohabitation without financial interdependence. This decision may impact future cases involving spousal support and cohabitation clauses, as it reinforces the need for clear evidence of shared financial responsibilities.
Moving forward, the ruling means that Amatha will continue to receive spousal support from Corey, as the court has reversed the termination order. The case also sets a precedent regarding the interpretation of cohabitation in Ohio, emphasizing that the legal definition requires more than just a romantic relationship. The court's decision may serve as a guideline for future disputes over similar issues.
As of now, it remains unclear if Corey will appeal the ruling. Additionally, there are no related cases pending that could affect this decision. The court's ruling stands, allowing Amatha to maintain her spousal support payments while clarifying the legal standards for cohabitation in Ohio.