Thompson v. Boivin

In Thompson v. Boivin, 1st Dist. No. C-010697, 2002 Ohio 4628, the Court held that the husband failed to meet the ten-percent test and was not entitled to a reduction in child support on that basis. Id. at P17. But we went on to hold that the trial court erred in dismissing the husband's motion to reduce child support "without affording him an opportunity to present evidence as to any change in circumstances, other than the ten-percent rule of R.C. 3119.79(A) that would justify a reduction in his child-support obligation."Id. at P19.