Robinson v. Robinson

Citations

• 2026 Ohio 2107

Syllabus

The trial court did not abuse its discretion in dismissing appellant-father's motion to modify parenting time and child support and converting appellant's support arrearages to a judgment. Appellant's motion was properly dismissed as a discovery sanction because appellant failed to comply with multiple court orders to provide discovery, including a financial disclosure affidavit required by local rules. Appellant's failure to provide discovery would have prejudiced appellee's and the trial court's abilities to examine his claim of changed circumstances at a hearing on his motion. The trial court did not err in converting the unpaid arrearages into a judgment because appellant's motion to modify support was dismissed and thus not pending at the time of the court's order. Judgment affirmed.