When Can Spousal Support Last Indefinitely in Ohio?
How long does spousal support last in Ohio? When an Ohio court awards spousal support, one of the most important questions is how long the payments will continue. Contrary to a common misconception, a long marriage does not automatically mean permanent spousal support.
Ohio Generally Favors Time-Limited Support
In Kunkle v. Kunkle, 51 Ohio St.3d 64 (1990), the Ohio Supreme Court established that spousal support should generally be limited to a reasonable period and terminate on a date certain when the recipient spouse has the ability and potential to become self-supporting.
Kunkle identified circumstances that may justify indefinite support, including:
- A marriage for a long duration;
- Parties of advanced age; or
- A spouse who has been a homemaker with limited opportunities to develop meaningful employment.
However, these circumstances do not automatically require indefinite support.
What Factors Determine How Long Spousal Support Lasts in Ohio?
Ohio Revised Code Section 3105.18 requires courts to consider numerous factors when determining whether spousal support is appropriate, including:
- Each spouse’s income and earning ability;
- Age and health;
- Retirement benefits;
- Length of the marriage;
- Employment and custodial responsibilities;
- Marital standard of living;
- Education;
- Assets and liabilities; and
- Each spouse’s contributions to the other’s education or earning ability.
The court must consider the circumstances as a whole rather than relying on a single factor.
Recent Ohio Cases
Recent Ohio appellate decisions help illustrate how long spousal support can last in Ohio and why the length of the marriage is only one factor courts consider. These decisions demonstrate that even a long marriage does not necessarily result in indefinite support.
In Adante v. Adante, 2024-Ohio-5371, the Eighth District upheld a six-year award following a 23-year marriage. Although the wife had medical conditions, she had worked outside the home and retained the ability to become self-supporting.
Likewise, Trainer v. Trainer, 2024-Ohio-1581, confirmed that marriages lasting 20 years or more do not automatically require indefinite support. Duration is only one of the factors courts must consider.
In Coxon v. Coxon, 2025-Ohio-2395, the court upheld a 72-month award despite the wife’s age and significant health problems because she remained employed full-time. (The parties had been married for about 24 years, and wife was approximately 52 years old at the time of the divorce,)
More recently, Mahoney v. Moskowitz, 2026-Ohio-1638, reaffirmed that the presence of a Kunkle factor does not require a court to award indefinite support.
The Bottom Line: How Long Does Spousal Support Last in Ohio?
How long does spousal support last in Ohio? There is no single answer that applies to every divorce. Ohio law generally favors spousal support that ends on a date certain, but courts have considerable discretion based on the circumstances of each case.
The length of the marriage matters, but so do the parties’ ages, health, income, employment history, assets, education, and ability to become financially self-sufficient. Even after a lengthy marriage, a court may determine that a time-limited award is appropriate.
In addition to the term or length of the spousal support, it is equally important to specify what continuing jurisdiction the Court retains to modify the amount paid as well as possibly extending the length of those payments.
If spousal support is an issue in your Ohio divorce or dissolution, an experienced family law attorney can help evaluate the statutory factors and determine what type and duration of support may be appropriate in your circumstances. Ther are many factors that must be carefully evaluated, many of which are quite subtle!
Experienced, Trusted and Professional Dayton Divorce Lawyers
MuesLaw can assist you with your divorce or dissolution related issues. To learn more, please go to our website at MuesLaw.com or call us at 937 293-2141. We can schedule an in-person conference or one by phone or Zoom. We look forward to assisting you!
PUBLISHER’S NOTE: I want to thank Ben Murakowski for helping to write this blog post! We are excited that Ben is clerking with MuesLaw. Ben has started his third and final year at the University of Dayton School of Law. You will be reading more from Ben in the weeks and months to come, as Ben will be staying on working with MuesLaw this Fall semester too! Well done, Ben!
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© 2026, Ohio Family Law Blog. All rights reserved.
Attorney Robert “Chip” Mues has been focusing his legal practice throughout Southwest Ohio primarily in divorce and family law matters since 1978. Chip is passionate about family law and has proudly published the Ohio Family Law Blog since 2007. In addition, he previously managed the Dayton law firm of Holzfaster, Cecil, McKnight & Mues LPA until it dissolved on December 31, 2024. He founded MUESLAW in 2025. To learn more about him or MUESLAW, visit www.MuesLaw.com. Appointments are available in person, over the phone or by Zoom. Call us at 937 293-2141. He can be contacted by email at chip@mueslaw.com.
