Tyra v. Griffith

Citations

• 2025 Ohio 912

Syllabus

DOMESTIC RELATIONS — PARENTING TIME — R.C. 3109.051(D) MODIFICATION — DUE PROCESS — CUMULATIVE EVIDENCE — NOTICE — FORFEITURE: The trial court did not abuse its discretion when it denied appellant-mother's motion to modify appellee-father's parenting time because evidence in the record of Father's progress in his relationship with his children supported the trial court's determination that an increase in parenting time was in the children's best interest under R.C. 3109.051. The trial court did not abuse its discretion when it limited appellant-mother's evidence to events that occurred after 2022 because evidence of appellee-father's 2013 conviction was cumulative to the evidence of that conviction that was already in the record, and because the trial court's temporal limitation was consistent with a 2022 agreed entry reinstating appellee-father's parenting time that the parties submitted six months after appellee-father was charged with domestic violence. Appellant-mother forfeited her challenge to the admission of the GAL's testimony on appeal because she failed to object to the GAL's testimony at the hearing and failed to argue that the admission of that testimony was plain error.