Massong v. Tyner

Citations

• 2022 Ohio 2933

Syllabus

CHILDREN – R.C. 3109.04(E) – CHANGE OF CIRCUMSTANCES – CUSTODY: In a parental-custody case, the trial court did not abuse its discretion by limiting father's parenting time where there was no change of circumstances, a best-interest analysis was not required, and the decision was not against the manifest weight of the evidence.