Cagle v. Cagle, 2022 Ohio 671

Parties divorced in 2020; Father was designated residential parent and legal custodian; Mother had parenting-time rights but had not exercised them since June 2020.
After the divorce Father learned the minor child (E.H.C.) was treated for anxiety; Mother repeatedly contacted the child’s pediatrician, therapist, and school raising unsubstantiated concerns (e.g., alleged environmental poisoning, GPS interference).
Mother allegedly interrupted a medical appointment by entering the exam room despite the child’s objection; police were summoned. A therapist obtained a cease-and-desist order prohibiting Mother from appearing at the child’s appointments or contacting the office.
Mother repeatedly sought the child’s school records; Father testified the child feared Mother would cause further disruptions at school and with providers and that Mother’s presence had provoked anxiety (e.g., blood-pressure spike).
In March 2021 Father moved for an order limiting Mother’s access to the child’s records and barring her from appearing at school, treatment providers, or workplace when the child was likely present; the trial court held a hearing and an in camera interview of the child and entered the restraint.
Trial court’s order required written permission before Mother may appear where the child is likely present and prohibited harassing personnel to obtain records; Mother appealed asserting factual error and that the order was not in the child’s best interest.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial court’s factual findings (disruptive conduct, interference with care) were supported	Father: testimony and provider notes show repeated interference and child anxiety	Mother: denies making abuse allegations at appointments and disputes multi-year disruptive conduct	Findings supported by competent, credible evidence; any stray error was harmless
Whether restricting Mother’s access to records violated statutory right under R.C. 3109.051(H)(1)	Father: order narrowly tailored and preserves access consistent with child’s best interest	Mother: practical effect will deny meaningful access because schools/providers could refuse consent	Order is a narrow, permissible restraint; does not eliminate statutory right and allows in-person access when child not likely present
Whether appellate review is barred by missing transcript of in‑camera interview (Knapp)	Father: Court need not address because record otherwise supports order	Mother: failed to provide transcript, so error cannot be reviewed	Court declined to rely on Knapp issue because record contained ample supporting evidence; reached merits
Whether harassment/appearance prohibition is overbroad or allows gatekeeping	Father: necessary to prevent disruption to child’s education and care	Mother: provision enables gatekeeping and effectively blocks access	Restriction narrowly targeted to prevent harassment and disruptions; not an abuse of discretion

Jindal Builders & Restoration Corp. v. Cincinnati Metro. Hous. Auth., 157 N.E.3d 279 (1st Dist. 2020) (appellate deference to trial-court factfinding; require "some competent and credible evidence")
MRI Software, L.L.C. v. W. Oaks Mall FL, L.L.C., 116 N.E.3d 694 (8th Dist. 2018) (same standard—appellate review looks for competent, credible evidence supporting findings)
Knapp v. Edwards Laboratories, 61 Ohio St.2d 197 (1980) (when portions of transcript necessary to decide assigned errors are omitted, reviewing court ordinarily must presume validity of lower-court proceedings)