Gessner v. Gessner

Citations

• 2017 Ohio 7514

Syllabus

Trial courts do not need to find a change of circumstances when considering modification of parenting time under R.C. 3109.04(E)(2)(b). However, even if a change of circumstances were required, the trial court did not abuse its discretion in finding that a change of substance occurred. Finally, the trial court did not abuse its discretion in concluding that an increase in Appellee's parenting time was in the children's best interests. Affirmed.