R.C. 3105.18 Interpretation

R.C. 3105.18 as it was amended in 1991, and in its current form, provides for purposes of modifying the amount or terms of spousal support, a change of circumstances includes, but is not limited to, any increase or involuntary decrease in the parties' wages, salary, bonuses, living expenses, or medical expenses. In Tsai v. Tien, 162 Ohio App. 3d 89, 2005 Ohio 3520, 832 N.E.2d 809, the Court found the statute requires more than a nominal change, but does not require a substantial or drastic change. Instead, the trial court need only determine whether a change occurred in the parties' economic status after the spousal support order was entered, and it is within the discretion of the trial court to determine whether a change has in fact occurred. Tsai at 93,.