Hammond v. Hammond

Citations

• 2019 Ohio 1219

Syllabus

CHILDREN – CUSTODY – R.C. 3109.04(B)(1): The trial court did not abuse its discretion by denying father's post-divorce decree motion for a change in custody, because the magistrate found there was no substance to father's assertion of a change in circumstances, a threshold factor for a change in custody, and father's objection to the finding was not supported by a transcript or other acceptable recording of all the evidence submitted to the magistrate relevant to that finding, including the magistrate's in-camera interview of the parties' oldest child. The trial court did not violate R.C. 3109.04(B)(1) by denying father's motion for a second in-camera interview of the child in a change-of-custody proceeding that had been referred to a magistrate, because the magistrate's in-camera interview of the child satisfied the requirement of the statute.