KOHLER v. CHAMBERS, 435 P.3d 109

Kelley P. Kohler (Father) and Carolynn L. Chambers (Mother) are biological parents of R.L.K.; they had an Agreed Decree of Paternity and Joint Custody Plan granting equal visitation.
Father received military orders to report for initial active duty for training (nine weeks basic training + nineteen weeks AIT) and could not take family with him.
Father filed a motion invoking the Oklahoma Deployed Parents Custody and Visitation Act (ODPCVA) seeking to designate his spouse to exercise his visitation rights during his absence.
The trial court granted the motion, concluding the training period qualified as a "deployment" under the ODPCVA; Mother moved to vacate and appealed after denial.
The Oklahoma Supreme Court considered whether attendance at basic training/AIT constitutes a "deployment" or makes a servicemember a "deploying parent" under 43 O.S.2011 §150.1(5).

Issue	Kohler's Argument	Chambers' Argument	Held
Whether mandatory initial active duty for training (basic + AIT) qualifies as a "deployment" under ODPCVA	Training orders are a deployment; ODPCVA protections apply and he may transfer visitation	Training is student/trainee service, not deployment; ODPCVA does not apply	Held: Training is not "in support of combat" and not a "deployment" under §150.1(5); Father is not a "deploying parent"

McClure v. ConocoPhillips Co., 142 P.3d 390 (Okla. 2006) (legislative silence can create ambiguity requiring statutory construction)
Hogg v. Okla. Cnty. Juvenile Bureau, 292 P.3d 29 (Okla. 2012) (courts must avoid constructions producing absurd results)
Cox v. Dawson, 911 P.2d 272 (Okla. 1996) (when a statute is unclear, courts may use extrinsic aids to determine intent)
In re Initiative Petition No. 397, 326 P.3d 496 (Okla. 2014) (statutory interpretation employs plain and ordinary meaning to ascertain legislative intent)
Birtciel v. Jones, 382 P.3d 1041 (Okla. 2016) (child's best interests are paramount in custody/visitation matters)