Bohannon v. Bohannon, 2020 Ohio 1255

Father and Mother divorced in 2010; Mother was residential parent and parties had an agreed parenting-time modification entered April 24, 2014 affecting their daughter K.
Father repeatedly objected to CSEA administrative child-support recommendations and filed three motions for contempt (June 2016, Oct 2016, Mar 2017) alleging Mother denied court-ordered parenting time and telephone contact.
On May 9, 2017, a magistrate limited the hearing to one hour; this Court reversed in Bohannon I (2018), finding the time restriction an abuse of discretion and remanding for a full hearing.
On remand the trial court held a two-day trial in January 2019; the court denied Father’s three contempt motions, overruled his objections to the CSEA recommendation, granted Mother’s motion to reallocate parental rights, and limited Father’s parenting time to contact once weekly and visitation as agreed between K and Father.
The record included GAL testimony that Mother generally tried to facilitate visits, evidence of a deteriorated relationship between Father and the then-teenage K (including counseling issues, police reports, and disputed communications), and the trial court found a change in circumstances caused by Father’s conduct.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial court disregarded the appellate mandate on remand	Bohannon: trial court effectively cut companionship to near zero, violating this Court’s remand directives	Mother: trial court complied — held a full two-day trial and ruled on all issues	Court: Overruled — remand complied with; ample opportunity to present evidence
Whether trial court erred in denying three contempt motions	Bohannon: Mother violated the April 2014 parenting-time order and should be held in contempt and forced to make up missed time	Mother: she made reasonable efforts, offered alternate schedules, and K. often refused or limited contact due to strained relationship; evidence insufficient	Court: Overruled — contempt not proven by clear and convincing evidence; trial court’s credibility findings upheld
Whether modification of parenting time was an abuse of discretion	Bohannon: modification effectively eliminates visitation and lacks proper best-interest/findings on parental fitness	Mother: there was a change in circumstances; court considered best-interest factors and limited contact appropriately to protect K.	Court: Overruled — modification within broad discretion; order limited contact but did not terminate rights and considered best-interest factors

Nolan v. Nolan, 11 Ohio St.3d 1 (rule that an inferior court must follow the appellate court's mandate)
Blakemore v. Blakemore, 5 Ohio St.3d 217 (abuse of discretion standard requires more than error of law or judgment)
Pons v. Ohio State Medical Board, 66 Ohio St.3d 619 (appellate review under abuse-of-discretion standard and limits on substituting judgment)
David v. Flickinger, 77 Ohio St.3d 415 (trial courts have broad discretion to modify parental rights)
Rossen v. Rossen, 2 Ohio App.2d 381 (party seeking contempt bears burden to prove noncompliance)