S.P. v. M.G.

Citations

• 2023 Ohio 2084

Syllabus

The trial court overruled appellant-father's a motion to reallocate parental rights or, in the alternative, to modifying his parenting time. The trial court did not abuse its discretion in denying Father's request for reallocation of parental rights because he failed to establish a change in circumstances. Based on its finding that there had been no change in circumstances, the trial court also denied Father's motion to modify parenting time. However, a change in circumstances is not required to modify the allocation of parenting time the only test is whether reallocation of parenting time is in the child's best interest. Therefore, the trial court erred by using an incorrect standard when deciding this portion of appellant's motion. Judgment affirmed in part, reversed in part, and remanded.