Javidan-Nejad v. Navadeh, 2011 Ohio 2283

Javidan-Nejad and Navadeh were married in Iran in 1996; they separated, had a son born in 2000, and had a separation agreement designating appellee as residential parent with a spousal and child support structure.
Two separation/addendum agreements in 2001 provided for large, structured spousal-support payments, deemed as complete satisfaction of any marital obligations and non-dischargeable in bankruptcy.
Post-divorce, Ohio trial court modified child support in 2005 due to changed circumstances; spousal-support provisions remained unresolved, and multiple post-decree motions were filed over the years.
In 2008–2009, proceedings progressed before a magistrate on various motions; the magistrate retained jurisdiction over spousal support modifications and set child-support figures and arrears.
In 2010, appellee moved to declare Ohio an inconvenient forum under R.C. 3127.21(A), arguing the child’s residence in California and connections there made California a more appropriate forum.
The trial court issued two judgment entries: the first declaring Ohio inconvenient for custody issues (transferring to California) and the second partially sustaining objections to the magistrate’s decision, leaving many issues unresolved.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Ohio was properly declined as a forum for custody issues	Javidan-Nejad contends the court abused discretion by relinquishing jurisdiction without proper evidence or hearing	Navadeh argues Ohio’s inconvenient-forum ruling was appropriate given California ties	Court held improper relinquishment of jurisdiction; evidentiary hearing and proper statutory process required
Whether the court’s failure to hold an evidentiary hearing on inconvenient forum was error	Javidan-Nejad asserts an evidentiary hearing was requested and required	Navadeh contends a hearing was unnecessary or had been effectively conducted by submissions	Abuse of discretion; hearing required
Whether the first judgment entry properly determined Ohio as inconvenient forum and whether that affected finality	Javidan-Nejad challenges the stay/transfer logic and finality of the order	Navadeh asserts the court acted within its authority to transfer; issues were unresolved anyway	First judgment entry reversed; case remanded to determine California forum; second entry deemed interlocutory and not reviewable here

Noble v. Colwell, 44 Ohio St.3d 92 (Ohio 1989) (finality and jurisdictional principles in divorce proceedings)
Critzer v. Critzer, 2008-Ohio-5126 (Ohio) (requirement of hearing when party requests; improper processing otherwise)
D.H. v. D.H., 2007-Ohio-4069 (Ohio) (abuse of discretion in inconvenient-forum considerations; appellate review standards)
Harris v. Harris, 2005-Ohio-6077 (Ohio) (standards for reviewing modifications and forum-related decisions)
Bowen v. Britton, 84 Ohio App.3d 473, 616 N.E.2d 1217 (Ohio App.3d 1993) (appellate review of substantial rights in domestic relations)