KECK v. KECK

2 Citing cases

  1. Hiscox v. Hiscox

    2008 Ohio 5209 (Ohio Ct. App. 2008)

    {ΒΆ 43} We have been unwilling to find an express reservation of jurisdiction to modify spousal support simply because boilerplate "until further order of the court" language is inserted at the end of a divorce decree. Keck v. Keck (Aug. 10, 2000), 7th Dist. No. 98 CA 247. However, when the trial court specifically states that the spousal support award itself shall continue until further order of the court, and when this statement occurs within the court's discussion of spousal support, we are presented with a much clearer indication that the court fully expected that it would have jurisdiction over subsequent spousal support orders.

  2. Hasselbach v. Hasselbach

    Court of Appeals No. S-00-004, Trial Court No. 91-DR-1031 (Ohio Ct. App. Nov. 30, 2000)   Cited 2 times
    In Hasselbach v. Hasselbach, 6th Dist. No. S-00-0004, 2000 Ohio App. LEXIS 5557 (Nov. 30, 2000), the divorce decree awarded spousal support to the wife for five years.

    As such, we find R.C. 3105.18(E) is inapplicable to the case at hand. See Keck v. Keck (Aug. 10, 2000), Mahoning App. No. 98 CA 247, unreported. Appellate courts have held that the trial court expressly reserved jurisdiction to modify spousal support with a variety of phrases, e.g., "all until further order of this court", Kopich v. Kopich (1998), 126 Ohio App.3d 332, and _Kirkwood v. Kirkwood (Sept. 4, 1996), Hamilton App. No. C-950940, unreported; "subject to further order of the court",Kearns v. Kearns (1990), 69 Ohio App.3d 305; and "until further order of the court", Meinke v. Meinke (1989), 56 Ohio App.3d 171.