In re B.T.-H.

Summary

The Ohio Ninth District Court of Appeals affirmed a judgment designating Father as the residential parent of the child and finding Mother in contempt for violations of parenting-time orders. The court held that the trial court’s best-interest findings were supported by competent, credible evidence and did not constitute an abuse of discretion or a manifest miscarriage of justice. The court also concluded that Mother forfeited most of her challenge to the contempt finding by failing to properly object to the magistrate’s decision.

Holdings

1. The trial court did not abuse its discretion or act against the manifest weight of the evidence in designating Father as the child's residential parent. The record contained competent, credible evidence supporting the trial court's best-interest determination.
2. Mother forfeited her challenge to the contempt finding concerning the July 11, 2019 parenting-time denial because she did not specifically object to that finding before the trial court and did not argue plain error. Her challenge concerning the September 13, 2019 incident did not demonstrate reversible error.

Questions Presented

1. Whether the trial court abused its discretion or reached a decision against the manifest weight of the evidence by designating Father as the child's residential parent under the best-interest factors in R.C. 3109.04.
2. Whether Mother preserved and established an appellate challenge to the contempt findings based on alleged violations of parenting-time orders.

Disposition

affirmed