Hall v. Hall, 2019 Ohio 81

Parents divorced in 2015 and adopted an agreed shared parenting plan providing equal time and requiring use of the Boys & Girls Club for Wednesday after‑school care when practicable.
Midway through the 2016 school year the Club stopped providing school-to-club transportation; Father could not drive from work and permitted the children (then ages 10 and 12) to stay at his home unsupervised until he returned from work.
Mother moved for contempt and to enforce continued use of the Club or, alternatively, that she be allowed to care for the children when Father was unavailable; Father moved to modify the plan to remove the Club requirement and defended his decision to leave the children briefly unsupervised.
A magistrate denied contempt, but modified Article 2 to require after‑school supervision: first by the possessing parent if available, otherwise the Boys & Girls Club (if transportation exists), otherwise Mother if available until 6:30 p.m., otherwise supervised care arranged at Father’s home.
Trial court adopted the magistrate’s decision; Father appealed arguing (1) the modification infringed his due‑process/fundamental parental rights and (2) the order was unclear/overbroad.

Issue	Mother’s Argument	Father’s Argument	Held
Did the court violate Father’s constitutional right to make day‑to‑day parenting decisions by ordering after‑school supervision?	Court should require supervision; children benefit from structured after‑school care; best interests favor supervision.	Father: as residential parent he may decide children can be left briefly unsupervised; modification infringes his fundamental liberty interest.	Modification reviewed under R.C. 3109.04(E)(2)(b) best‑interest standard; court considered parents’ wishes and other factors and did not abuse discretion. No due‑process violation.
Was the modification overbroad or unclear (duration and notification timing)?	Order permits mutual agreement or future modification; practical default rules provided for when parents disagree.	Order effectively mandates after‑school care until emancipation and fails to set notice timeframe for Mother’s availability.	Order is not overbroad or unclear; parties may amend by agreement or move for future modification when maturity warrants; Father bears obligation to arrange supervision if Mother does not respond/is unavailable.

Troxel v. Granville, 530 U.S. 57 (2000) (parents have a fundamental liberty interest in care, custody, and management of their children)
Santosky v. Kramer, 455 U.S. 745 (1982) (due‑process protections in parental liberty interests)
Blakemore v. Blakemore, 5 Ohio St.3d 217 (1983) (abuse‑of‑discretion standard defined for appellate review)
Harold v. Collier, 107 Ohio St.3d 44 (2005) (parental wishes must be considered but not placed above child’s best interest)