In re E.R.

Citations

• 2019 Ohio 4491

Syllabus

CHILDREN – CUSTODY – CHANGE IN CIRCUMSTANCES – R.C. 3109.04: The juvenile court erred in sustaining mother's objections to the magistrate's decision, which determined that a change in the child's circumstances had occurred and modified legal custody of the child from mother to father, where the juvenile court required a showing of a \substantial\ change in the child's circumstances, a higher burden than that imposed by R.C. 3109.04, to modify the custody of the child.