Liles v. Doyle, 2014 Ohio 1681

Child K.J.D.’s mother died in a house fire (Dec. 26, 2011); father Dumond D. Liles sought legal custody (filed Jan. 18, 2012).
Maternal cousin/godmother Jacki Querry intervened and moved for legal custody; the magistrate granted Jacki temporary custody and set visitation/support.
Two-day evidentiary hearing was held; magistrate awarded legal custody to Jacki; trial court adopted the magistrate’s decision and denied Liles’ objections.
Key factual findings: Liles has many children, a history of intermittent/infrequent involvement with them and with K.J.D., prior incarcerations and criminal convictions, a cash-based self-employment, inconsistent visitation and support payments.
Jacki and her husband provided a stable household where K.J.D. had established relationships; maternal grandmother Mary also cared for the child and supported Jacki’s custodial claim.

Issue	Plaintiff's Argument (Liles)	Defendant's Argument (Jacki)	Held
Whether father was "unsuitable" so that awarding him legal custody would be detrimental to the child	Liles argued he had an established relationship, provided in-kind support and some payments, and that evidence did not show awarding him custody would harm the child	Jacki argued Liles lacked sustained involvement, failed to timely follow visitation/support obligations, and could not provide the stability the child needed	Court held sufficient credible evidence supported finding Liles unsuitable and that awarding him custody would be detrimental; custody to Jacki affirmed
Standard of review: whether trial court abused its discretion in custody decision	Liles contended the court abused its discretion in finding him unsuitable	Jacki and court relied on trial court’s broad discretion in child-welfare determinations and testimonial credibility findings	Court applied abuse-of-discretion review and found no abuse; decision was reasonable and supported by the record

In re Hayes, 79 Ohio St.3d 46 (discusses parental custody as a fundamental right and requires procedural protections)
In re Murray, 52 Ohio St.3d 155 (recognizes parental custody as a substantial right)
In re Perales, 52 Ohio St.2d 89 (establishes circumstances when parent may be denied custody in favor of nonparent)
Reynolds v. Goll, 75 Ohio St.3d 121 (emphasizes trial court discretion in child-custody matters)
Trickey v. Trickey, 158 Ohio St. 9 (historical recognition of trial court discretion in custody)
Masters v. Masters, 69 Ohio St.3d 83 (standard for reviewing trial court custody decisions)
Blakemore v. Blakemore, 5 Ohio St.3d 217 (defines abuse of discretion as unreasonable, arbitrary, or unconscionable)
In re Hockstok, 98 Ohio St.3d 238 (applies Perales standards to parent vs. nonparent custody disputes)