Waller v. Waller

In Waller v. Waller (2005), 163 Ohio App. 3d 303, 2005 Ohio 4891, 837 N.E.2d 843, the Court held that a trial court cannot order a spousal support obligor to maintain life insurance as security for a support obligation when that obligation expressly terminates upon the death of the obligor. In that case, life insurance was required to be maintained in full during the ten-year duration of a spousal support award, only, with no provision for the gradual reduction of the amount of life insurance required as the spousal support awarded was paid. The appellate court found ambiguity as to whether the trial court intended that the spousal support should continue after the obligor's death, and remanded the cause for clarification of that issue.