Evans-Dorn v. Dorn, 2015 Ohio 5032

Heather Evans-Dorn (Mother) and Matthew Dorn (Father) divorced after Father moved to North Carolina; child E.D. born Oct. 26, 2011. Mother initially named residential parent in a temporary order.
Dispute over custody: Mother sought primary residential parent under a shared parenting plan; Father sought sole custody or shared parenting.
Court ordered a parenting investigation and appointed a guardian ad litem (GAL). GAL initially recommended shared parenting with Mother primary, then later recommended shared parenting with Father primary in North Carolina.
Trial court conducted a two‑day final hearing and considered testimony about parental care, stability, routines, mental/physical health, geographic distance (~430 miles), and communication problems between the parents.
Court found concerns about Mother’s stability, housing moves, missed appointments, inconsistent routines for the children, interference with Father’s parenting time, and Father’s more structured schedule and support network. Court denied shared parenting and awarded Father sole residential and legal custody; Mother given 9 consecutive days/month parenting time.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial court erred in awarding Father sole custody instead of naming Mother residential parent	Mother: Awarding Father custody is not in E.D.'s best interest; Mother can facilitate visitation and order details can prevent interference	Father: He provides more structure, stability, support network, and will facilitate child’s needs; Mother has unstable housing, missed appointments, and interferes with visitation	Court: No abuse of discretion; found evidence supported Father as residential parent and denial of shared parenting

Blakemore v. Blakemore, 5 Ohio St.3d 217 (Ohio 1983) (defines abuse of discretion standard for appellate review)