In re K.R.H.

Citations

• 2026 Ohio 583

Syllabus

The trial court did not abuse its discretion when it modified father's parenting time with his son to the Standard Order of Parenting Time. The standard order remedied the parties' shared concern regarding the consistency of parenting time, and the trial court appropriately considered the statutory best interest factors of R.C. 3109.051(D). The trial court abused its discretion when it limited father's parenting time with his daughter to therapy sessions only, with modifications within the therapist's sole discretion. The record does not reflect that this would be in the child's best interest. Judgment affirmed in part, reversed in part, and remanded.