40 Ohio App. 3d 92 - Rohrbach v. Rohrbach’s Empirical Analysis

Citation profile

7 state decisions

Most-quoted passages

The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 7 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “When a support order due an obligee would have a variance in excess of ten percent (10%), that variance shall be deemed to be a change of circumstance which may be considered by the court in determining whether all the changes of circumstance are substantial enough to require a modification of the support order. The court shall determine from applicable statutory and case law whether the change of circumstance is substantial and not contemplated at the time of the last prior order. If the court then determines that a change in support is merited, it is not mandatory that the child support be modified to the level of the guidelines.”

   1 later decision quote this exact passage
   e.g. Baird v. Baird

2. “change of circumstances The guidelines provide: "[Wlhen a support order due an obligee would have a variance in excess of 10%, that variance shall be deemed to be substantial change of circumstance to justify a modification. C.P. Sup.R. 75(B). "All the obligee need show is a difference in excess of ten percent between the existing child support payments and the child support payments under the guidelines. If the obligee can meet this requirement, the step requiring a showing of a change of circumstances has been satisfied.”

   1 later decision quote this exact passage
   e.g. McGann v. McGann

3. “Modification of child support is a two-step process. The moving party must first show a change in circumstances Second, based on these circumstances as well as any other relevant factors, modification may be fashioned by the court.”

   1 later decision quote this exact passage
   e.g. McGann v. McGann