In re D.H.

Citations

• 2026 Ohio 2182

Syllabus

Juvenile court; shared parenting; child support; refresh recollection; Evid.R. 801(C); hearsay evidence; Evid.R. 612; harmless error; supervised parenting time; voluntarily underemployed; voluntarily unemployed; imputed income; bootstrapping; abuse of discretion. The trial court erred when it allowed paternal grandmother to testify to the contents of several police reports. The error, however, was harmless because there was no evidence that the trial court considered the reports in rendering its decision. The trial court considered the proper factors in ordering supervised parenting time. The trial court did not abuse its discretion in ordering Father to pay child support by finding that Father was voluntarily underemployed or voluntarily unemployed. The proper parties were joined to the case. The issue of the children's surnames is not properly before this court because Father failed to timely appeal the issue.