A.R.C. v. D.J.S., 2020 Ohio 5403

Parties divorced (Nov. 28, 2017); mother (A.R.C.) designated residential parent and sole legal custodian of the minor child.
Divorce decree limited father D.J.S. to supervised parenting time "as the parties shall agree," and barred court-ordered parenting time unless requested by motion.
Father moved (Feb. 2018) for unsupervised every-other-weekend visitation; magistrate ordered supervised visits through an agency and incremental increase, with prerequisites for unsupervised time (parenting classes, domestic-violence/anger-management, six consecutive months of clean 10-panel drug screens, etc.).
Father has a history of mental-health and polysubstance issues, two domestic-violence convictions involving the mother, additional criminal convictions, and inconsistent contact with the child; guardian ad litem recommended continued supervised visits.
Father filed multiple motions (contempt re missed supervised visits; motions to modify visitation claiming completion of programs). Magistrate denied contempt and, on Nov. 21, 2019, denied change to unsupervised visitation because father had not demonstrated compliance with prerequisites.
On appeal father challenged the supervised-visitation order; appellate court affirmed, noting absence of a transcript, failure to timely object below, partial noncompliance with conditions, and lack of supporting exhibits.

Issue	Plaintiff's Argument (A.R.C.)	Defendant's Argument (D.J.S.)	Held
Whether the trial court erred by ordering supervised visitation and denying unsupervised visitation	Supervised visitation is appropriate given child-safety concerns, father’s mental-health, substance-abuse history, criminal and DV record, and GAL recommendation	Father says he completed programs, has had supervised visits, and seeks unsupervised weekends/holidays; contests court’s handling of his motions	Court affirmed supervised visitation; father had not met the court-ordered conditions for unsupervised visitation and record supports continued supervision
Whether contempt and modification motions were overlooked or improperly denied	Court addressed the motions (May 10, 2018 order; July 1, 2019 magistrate decisions; Nov. 21, 2019 denial)	Father contends motions were overlooked and not addressed	Court found motions were decided; contempt motion denied and modification motion denied — no unresolved modification motion at time of appeal
Standard of appellate review given missing transcript and lack of timely objections	A.R.C.: no reversible error; proceedings presumed regular absent transcript and objections	D.J.S.: asserts error in magistrate/trial-court rulings and seeks reversal	Appellate court reviewed only for plain error; absent a proper transcript and timely objections, court presumed regularity and affirmed; appellant bears transcript obligation

Braatz v. Braatz, 85 Ohio St.3d 40 (1999) (modification of visitation governed by R.C. 3109.051; trial court must consider statutory factors and exercise discretion)