Mandelbaum v. Mandelbaum

{¶ 1} This case is presented on a certified conflict and on Stanley Mandelbaum’s appeal from a decision of the Montgomery County Court of Appeals that reversed an order of the domestic relations court reducing his spousal support payments to his ex-wife, Frances Mandelbaum. The certified question presented in this case is whether a trial court may modify a prior order of spousal support without finding that a substantial change in the circumstances of the parties has occurred and that the parties had not contemplated such a change at the time of the original divorce decree.

{¶ 2} The Second…