Humphrey v. Humphrey

Summary

The Fifth District Court of Appeals of Ohio affirmed the Holmes County Court of Common Pleas’ judgment designating the father as the residential parent and legal custodian of the parties’ minor child. The court upheld the mother’s contempt finding based on violations of parenting-time orders and rejected her challenge to the child-support calculation under the invited-error doctrine. The court applied Ohio’s best-interest factors and abuse-of-discretion standards.

Holdings

1. The trial court did not abuse its discretion by designating Husband as residential parent and legal custodian of B.H. and allocating parental rights and responsibilities in accordance with B.H.'s best interests.
2. The trial court did not abuse its discretion by finding Wife in contempt for denying or interfering with Husband's court-ordered parenting time.
3. Wife could not obtain reversal based on the trial court's failure to consider additional income evidence because she expressly opposed presenting that evidence at the magistrate's clarification hearing and therefore invited the alleged error.

Questions Presented

1. Whether the trial court abused its discretion by designating Husband as residential parent and legal custodian and allocating parental rights and responsibilities under the statutory best-interest factors.
2. Whether the trial court abused its discretion by 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 evidence available after Wife opposed the presentation of additional income evidence at the clarification hearing.

Disposition

affirmed