L.G. v. R.G.

Citations

• 2026 Ohio 258

Syllabus

Abuse of discretion, de novo review, competent credible evidence, R.C. 3127.16, continuing jurisdiction, exclusive jurisdiction, subject-matter jurisdiction, intent to relocate, R.C. 3109.05(G)(1), change of circumstances, best interest, R.C. 3109.04(F)(1), alienation, terminating spousal support, child support, imputed income, R.C. 3119.01, R.C. 3119.02, attorney fees, R.C. 3105.73(B). Judgment affirmed. We find that the trial court had subject-matter jurisdiction over the parties even though none of the parties resided in Ohio because once Ohio courts obtained jurisdiction over a child-custody determination, it retains continuing jurisdiction, even when the parties no longer reside in Ohio, so long as no other court has asserted jurisdiction. Further, a notice of relocation does not strip the trial court of jurisdiction to modify parental rights and responsibilities when a motion is pending before the court. There was competent, credible evidence of a change of circumstances and that it was in the best interest of the children to modify custody. In addition, spousal support was properly terminated. Moreover, ordering appellant to pay child support was not an abuse of discretion, and imputing income to appellant was proper when she was voluntarily unemployed. Finally, the trial court is not required to consider appellant's income when awarding attorney fees.