In re K.R.H.

2026-Ohio-583 · Court of Appeals of Ohio, Second Appellate District, Montgomery County · February 20, 2026 · No. 30587

Summary

The Ohio Second District Court of Appeals reviewed modifications to a father's parenting time with two minor children. The court affirmed the modification concerning C.H., reversed the limitation of parenting time with K.R.H. to therapy sessions at the therapist's discretion, and remanded for further proceedings.

Holdings

  1. The trial court did not abuse its discretion by modifying Father's parenting time with C.H. to the Standard Order of Parenting Time.
  2. The trial court abused its discretion by limiting Father's parenting time with K.R.H. to therapy sessions and by making any modification dependent solely on the therapist's discretion.

Questions Presented

  1. Whether the trial court abused its discretion by modifying Father's parenting time with C.H. to the Standard Order of Parenting Time.
  2. Whether the trial court abused its discretion by limiting Father's parenting time with K.R.H. to therapy sessions and placing any modification solely within the therapist's discretion.

Disposition

reversed_and_remanded

Cases Cited (10)

  • Shoenfelt v. Shoenfelt, 2009-Ohio-6594, ¶ 7 (2d Dist.)(followed)
  • Blakemore v. Blakemore, 5 Ohio St.3d 217, 219 (1983)(followed)
  • State v. Malloy, 2012-Ohio-2664, ¶ 24 (2d Dist.)(followed)
  • In re E.R., 2022-Ohio-3658, ¶ 9 (2d Dist.)(followed)
  • Braatz v. Braatz, 85 Ohio St.3d 40, 45 (1999)(followed)
  • Palichat v. Palichat, 2019-Ohio-1379, ¶¶ 28, 33-36 (2d Dist.)(followed)
  • Hutchinson v. Hutchinson, 2014-Ohio-4604, ¶ 32 (2d Dist.)(followed)
  • Doane v. Doane, 2001 WL 474267, *6 (5th Dist. May 2, 2001)(followed)
  • In re E.M.W., 2009-Ohio-3016, ¶ 18 (2d Dist.)(followed)
  • Smith v. Quigg, 2006-Ohio-1495, ¶ 66 (5th Dist.)(followed)

Cited In (0)

No citing cases on record yet.

Court Document

Open PDF
Loading document…

More from Ohio Court Of Appeals Second Appellate District Montgomery County Court Of Appeals Of Ohio Second Ap