Wilcox v. Iiams

Citations

• 2019 Ohio 3030

Syllabus

R.C. 3109.04(E)(2)(b) applies to the modifications of a shared parenting plan and only requires a trial court to determine that the modification is in the best interest of the child. R.C. 3109.04(E)(1)(a) applies to modifications of a shared parenting decree and does require a trial court to find a change of circumstances in order to modify the decree.