J.T. v. L.H.

2024 Ohio 4615
CourtOhio Court of Appeals
DecidedSeptember 20, 2024
DocketE-23-055
StatusPublished

This text of 2024 Ohio 4615 (J.T. v. L.H.) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
J.T. v. L.H., 2024 Ohio 4615 (Ohio Ct. App. 2024).

Opinion

[Cite as J.T. v. L.H., 2024-Ohio-4615.]

IN THE COURT OF APPEALS OF OHIO SIXTH APPELLATE DISTRICT ERIE COUNTY

J.T. Court of Appeals No. E-23-055

Appellant Trial Court No. 2022 JB 0016

v.

L.H. DECISION AND JUDGMENT

Appellee Decided: September 20, 2024

*****

Gina M. McNea, for appellant.

Shelly L. Kennedy, for appellee.

DUHART, J.

{¶ 1} This is an appeal by appellant, Joshua Tucker (“father”), from the October

31, 2023 judgment of the Erie County Court of Common Pleas, Juvenile Division, which

granted appellee, Lisa Hauck (“mother”), custody of their child. For the reasons that

follow, we affirm the judgment.

{¶ 2} Father sets forth one assignment of error:

The Trial Court abused it’s [sic] discretion when it made

conclusions that are unreasonable, arbitrary and unconscionable, that are not based upon the evidence and testimony adduced at

Trial and improperly weights [sic] O.R.C. 3109.04 (F)(1), best

interest factors.

Background

{¶ 3} In 2012, mother and father were in an on-again, off-again relationship, when

in December, mother gave birth to child, A.T. Mother and father were not married and

did not live together, but paternity of the child was not disputed. The parents had not

legally established their parental rights and responsibilities for the child, but the parents

lived near each other and worked together to raise their child for a long period of time.

By operation of law,1 mother was the child’s residential parent and legal custodian.

Child Support

{¶ 4} In February 2014, a child support order was issued by the Erie County Child

Support Enforcement Agency (“CSEA”), establishing father as obligor and mother as

obligee. Father was ordered to pay $249.63 per month for child support, plus a

processing fee (“fee”). Then, in January 2015, father was ordered to pay, when private

health insurance was provided for the child, $332.05 per month for current child support,

plus a fee, and when private health insurance was not provided, $249.63 per month for

current support, plus a fee. Father was also ordered to pay $66.41 monthly on arrears,

plus a fee.

1 R.C. 3109.042(A) (“An unmarried female who gives birth to a child is the sole residential parent and legal custodian of the child until a court . . . issues an order designating another person as the residential parent and legal custodian.”).

2. {¶ 5} In July 2015, CSEA filed a motion to show cause asking that father appear

and show cause why he should not be punished for failing to make child support

payments. In October 2015, father was found in contempt of court for failing to pay

support and was sentenced to 30 days in jail, which sentence was stayed, with purge

conditions set. In June 2017, CSEA filed a motion for imposition of sentence, requesting

that father’s jail sentence be imposed. In October 2017, father was ordered to report to

jail to serve 10 days in full satisfaction of the 30 days previously ordered.

{¶ 6} In July 2022, mother filed a motion to show cause requesting father appear

and show cause why he should not be held in contempt for failing to pay child support.

{¶ 7} In February 2023, a trial was held on, inter alia, the child support matter.

{¶ 8} In April 2023, the magistrate issued a decision in which he found that father

was in contempt for failing to pay child support. The magistrate recommended that

father be sentenced to 60 days in jail and pay a fine and court costs, but the magistrate

proposed that father be allowed to purge himself of the contempt upon meeting certain

conditions.

{¶ 9} On October 31, 2023, the juvenile court found father in contempt for failing

to pay child support. The court sentenced father to 60 days in jail, the usual sentence for

a second contempt finding per R.C. 2705.05(A)(2) and ordered father to pay a fine and

court costs. Father did not appeal the child support issue.

3. Parental Rights and Responsibilities

{¶ 10} In February 2022, father filed a Complaint for Parentage, Allocation of

Parental Rights and Responsibilities (Custody), seeking custody of the child.

{¶ 11} In February 2023, a trial was held on, inter alia, father’s complaint, as

mother wanted to keep custody of the child. Testimony from father, mother, the principal

at the child’s school, and father’s sister was presented, 29 exhibits were offered into

evidence and 21 exhibits were admitted.

{¶ 12} In April 2023, the magistrate issued a decision in which he recommended

that father’s complaint be granted, and father be designated the residential parent and

legal custodian of the child. Mother filed objections.

{¶ 13} On October 31, 2023, the juvenile court issued its judgment. The court

denied mother’s objections on technical grounds and undertook a de novo review of the

matter, considering the evidence in the trial transcript and the exhibits. The court found

the magistrate’s recommendation to designate father as the residential parent was

“inconsistent with the fact that Father . . . never appropriately fulfilled his responsibility

to pay child support and it [was] not in the child’s best interests to allocate primary

responsibilities to one who has shown a disregard for [his] responsibilities.” The court

denied father’s complaint, in part as to custody, and granted the complaint, in part as to

visitation. The court ordered that mother be the residential parent and legal custodian of

the child, and father was entitled to visitation with the child, either by agreement of the

parties or pursuant to the court’s standard schedule for parenting time.

4. {¶ 14} Father appealed the custody determination.

R.C. 3109.04

{¶ 15} R.C. 3109.04 sets forth the provisions for the allocation of parental rights

and responsibilities. When making such an allocation, the juvenile court “shall take into

account that which would be in the best interest of the child[].” R.C. 3109.04(B)(1). In

determining the best interest of a child, R.C. 3109.04(F)(1) provides that the juvenile

court “shall consider all relevant factors, including, but not limited to” the following:

(a) The wishes of the child’s parents regarding the child’s care;

(b) If the court has interviewed the child in chambers . . . regarding the

child’s wishes and concerns as to the allocation of parental rights and

responsibilities concerning the child, the wishes and concerns of the child,

as expressed to the court;

(c) The child’s interaction and interrelationship with the child’s parents,

siblings, and any other person who may significantly affect the child’s best

interest;

(d) The child’s adjustment to the child’s home, school, and community;

(e) The mental and physical health of all persons involved in the situation;

(f) The parent more likely to honor and facilitate court-approved parenting

time rights or visitation and companionship rights;

5. (g) Whether either parent has failed to make all child support payments,

including all arrearages, that are required of that parent pursuant to a child

support order under which that parent is an obligor . . . [.]

Juv.R. 40

{¶ 16} Juv.R. 40 governs magistrate’s decisions and the procedure for filing and

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Bluebook (online)
2024 Ohio 4615, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jt-v-lh-ohioctapp-2024.