Napier v. Kelley

Citations

• 2026 Ohio 1700

Syllabus

The manifest weight of the evidence demonstrates that respondent threatened petitioner via social media posts, justifying the issuance of a DVCPO by the trial court. However, there is no evidence in the record that respondent threatened the parties' shared child in the posts, meaning the trial court erred by including the child in the order. Setting the duration of the DVCPO at five years was unreasonable—constituting an abuse of discretion—because there is no clear indication of the court's underlying reasoning and analysis for that duration.