Humphrey v. Humphrey

Summary

The Ohio Fifth District Court of Appeals affirmed a Holmes County domestic-relations judgment designating the father as the residential parent and legal custodian of the parties’ minor child. The court upheld the mother’s contempt finding for violating parenting-time orders and rejected her challenge to the child-support calculation under the invited-error doctrine.

Holdings

1. The trial court did not abuse its discretion in designating Husband as the residential parent and legal custodian because its findings under the applicable statutory best-interest factors were supported by relevant, competent, and credible evidence.
2. The trial court did not abuse its discretion in finding Wife in contempt for violating court-ordered parenting-time provisions.
3. Wife could not establish reversible error in the child-support calculation because she invited the alleged error by expressly opposing the presentation of additional income evidence at the magistrate's clarification hearing.

Questions Presented

1. Whether the trial court abused its discretion in designating Husband as the residential parent and allocating parental rights and responsibilities under Ohio's best-interest factors.
2. Whether the trial court abused its discretion in finding Wife in contempt for violating court-ordered parenting-time provisions.
3. Whether the trial court erred in calculating child support by relying on the available income evidence after Wife opposed the presentation of additional evidence at the clarification hearing.

Disposition

affirmed