May Juvenile Court Adopt Parents’ Agreement To Reduce or Forgive Child Support Arrearage?
Christina Lynn Byrd n.k.a. Reeder v. Brian Kelly Knuckles, Case no. 2007-1913 12th District Court of Appeals (Clermont County) ISSUE: Does Ohio law allow a juvenile court to ratify an agreement to reduce or forgive an existing arrearage in child support payments when that agreement has been voluntarily entered into by the obligor and obligee parents? If so, does a court abuse its discretion by refusing to adopt an agreement between parents to forgive or abate a child support arrearage without making findings supporting a conclusion that the abatement agreement between the parents is unreasonable? BACKGROUND: In this case, the Court is asked to determine whether Ohio’s child support statutes barred the Clermont County Juvenile Court from adopting a reduction in the amount of a pre-existing child support arrearage to reflect an agreement between Brian Knuckles, a father who was delinquent in paying child support, and Christina Byrd Reeder, the custodial mother to whom that support was ow
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