In re T.M.

Citations

• 2020 Ohio 6950

Syllabus

CHILDREN — CUSTODY — VISITATION — PROCEDURE/RULES: The record does not establish that the trial court failed to commence the disposition hearing in this case outside the deadline established in R.C. 2151.35(B)(1). Even though the trial court failed to clearly analyze the statutory factors set forth in R.C. 2151.414(D), the record indicates that the trial court considered the best interest of the children in this case and—while a close case—the decision to award custody was not an abuse of discretion. The trial court abused its discretion when it revoked mother's visitation rights without giving a reason for doing so and where the record contains no indication that the court considered the R.C. 3109.051(D) factors.