In re L.J.S., 2016 Ohio 8107

Background

Unmarried parents Christopher Starcher (appellant) and Ashley Lynch (appellee) share a two-year-old child; after separation Lynch and the child moved seven hours away to Pennsylvania.
Starcher filed for designation as residential parent or, alternatively, shared parenting in Feb 2015.
A magistrate (Sept 9, 2015) named Lynch residential parent and legal custodian, awarded Starcher rotating two-week parenting time until school age, and ordered a 50% downward deviation in child support while the child lived fifty percent with each parent.
The trial court initially adopted the magistrate’s decisions on Sept 9, 2015. Lynch later objected to the rotating two-week parenting time and sought adoption of the court’s standard parenting time policy and an adjustment to child support.
On Mar 11, 2016 the trial court sustained Lynch’s objection, ordered parenting time per the court’s standard policy and adjusted annual child support amounts, but did not unambiguously state whether it vacated, modified, or adhered to its prior Sept 9 judgments.
The appellate court dismissed the appeal for lack of a final, appealable order because the March 11 entry failed to clearly terminate the matter or lift the automatic stay on the Sept 9 judgments.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Finality / jurisdiction: Is the Mar 11, 2016 order final and appealable?	Starcher treated the March 11 order as final and appealed the modification reducing his parenting time.	Lynch argued the court resolved objections and effectuated modifications; trial court believed it had adopted standard policy.	Appeal dismissed: March 11 entry was not a final, appealable order because it did not unambiguously vacate/modify/adhere to the Sept 9 judgments and did not set all parties’ rights in a single document.
Parenting time standard: Whether magistrate’s nearly-equal rotating schedule was permissible when parties live far apart and sole custody awarded.	Starcher favored the magistrate’s equal rotating schedule (practical parenting arrangement).	Lynch argued the magistrate’s rotating schedule was improper given sole custody award and seven-hour distance; requested standard parenting time policy.	Court noted discretion to craft parenting time under child's best interest but found the trial court’s March 11 entry unclear; substantive ruling on parenting-plan appropriateness was not finally reviewable here.
Child support deviation: Whether downward deviation based on fifty-percent parenting time was valid and properly journalized.	Starcher relied on magistrate’s deviation and annual payment schedule.	Lynch sought recalculation under standard parenting time and adjustment of support.	Appellate court flagged that the Sept 9 child support entry’s compliance with Marker requirements was questionable but did not resolve it because of lack of final order.
Trial court obligation: Must the trial court enter a single clear judgment disposing of rights after magistrate decision and objections?	Starcher implicitly relied on trial court’s March 11 modifications constituting final disposition.	Lynch relied on trial court procedure and argued for implementation of standard policy; trial court issued modifications but not a clear single-document judgment.	Held: Trial court must enter an independent, unambiguous judgment specifying whether it vacated, modified, or adhered to earlier judgments; failure to do so prevents appellate jurisdiction.

Key Cases Cited

Gehm v. Timberline Post & Frame, 112 Ohio St.3d 514 (2007) (order must be final before appellate review)
State ex rel. Boddie v. Franklin Cty., 135 Ohio St.3d 248 (2013) (magistrate decisions are not final; trial court retains responsibility)
Burns v. Morgan, 165 Ohio App.3d 694 (2006) (trial court must enter independent judgment after magistrate decision)
Harkai v. Scherba Indus., Inc., 136 Ohio App.3d 211 (1999) (judgment must be definite enough for enforcement and to inform parties of rights)