In re N.J.V.

Citations

• 2025 Ohio 375

Syllabus

Modifications of shared-parenting plans and decrees; R.C. 3109.04; modification in the designation of the residential parent for school purposes; changes in circumstances; best interest of child. The trial court erred in finding that mother's motion to change a designation of the residential parent for school purposes is governed by R.C. 3109.04(E)(1)(a), which requires a demonstration of a change in circumstances. The trial court's judgment is affirmed, however, because it denied mother's motion on an alternative ground that the modification would not serve the child's best interest, and our review indicates the trial court did not abuse its discretion in its best-interest finding.