In re I.J.

Citations

• 2026 Ohio 1191

Syllabus

Parental rights and responsibilities; modification; change in circumstances; R.C. 3109.04(E); best interests; R.C. 3109.051(D); witness list; exhibit list; Guardian ad litem (\GAL\); fees; local rules; abuse of discretion. Judgment affirmed. The juvenile court did not abuse its discretion by modifying the parties' parental rights and responsibilities agreement and declining to find a change in circumstances. The juvenile court exercised sound discretion when allowing the child's half-brother to testify and allowing certain exhibits from Father even though Mother's witness list and Father's supplemental exhibit list were untimely. Father failed to demonstrate a change in circumstances under R.C. 3109.04(E) to warrant a change in Mother's status as residential parent and legal custodian. Additionally, the modifications by the court to the agreement were in the child's best interest under R.C. 3109.051(D). Lastly, the court did not err when it denied in part Father's motion to exclude the GAL report. The court remedied any error by striking the improper legal conclusions by the GAL regarding change in circumstances and allowed the GAL to testify regarding the child's best interests. The court complied with the local rules by allowing Father 14 days to request a hearing on the GAL's motion for fees prior to ruling on the motion.