Wolford v. Willis

Citations

• 2018 Ohio 3937

Syllabus

Modify prior decree allocating parental rights–trial court did not abuse its discretion by declining to follow guardian ad litem's recommendation when appellant failed to establish threshold requirement of change in circumstances any error trial court may have committed by discounting counselors' testimony constituted harmless error trial court did not abuse its discretion by determining change in circumstances had not occurred when appellant attempted to re-litigate same facts and issues parties presented during earlier proceeding involving appellee's motion to modify and when any difficulties were pre-existing and of appellant's own making.