Curtis v. Curtis, 2012 Ohio 4855

Jamaica (Mother) and Chad (Father) Curtis divorced in August 2010, with a shared-parenting decree.
Both sought termination of shared parenting; case referred to a magistrate for investigation and recommendation.
Magistrate recommended continuing shared parenting with modifications; parties objected to that recommendation.
Trial court largely rejected the magistrate’s decision and terminated shared parenting, designating Father as residential parent and legal custodian.
Mother appeals the designation of Father as custodial parent, challenging abuse of discretion and weight of the evidence.
Court considered statutory framework under R.C. 3109.04 and related case law; hospitalities and conduct supporting termination of shared parenting.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether designation of Father as custodial parent was an abuse of discretion	Curtis contends designation is against the weight of evidence	Curtis argues Father is better suited and more reliable	No abuse; designation upheld

Beismann v. Beismann, 2d Dist. Montgomery No. 22323, 2008-Ohio-984 (Ohio 2008) (best-interests standard; review for abuse of discretion in custody)
Miller v. Miller, Ohio St.3d 71, 523 N.E.2d 846 (1988) (trial court custody discretion warrants respect)
Eastley v. Volkman, 2012-Ohio-2179 (Ohio Supreme Court 2012) (weight-of-evidence standard; defer to trial court on credibility)
Thompkins, 78 Ohio St.3d 380, 678 N.E.2d 541 (Ohio 1997) (weight of evidence framework in reviewing findings)
Blakemore v. Blakemore, 5 Ohio St.3d 217, 450 N.E.2d 1140 (Ohio 1983) (abuse of discretion standard in custody cases)