Tisci v. Smith, 60 N.E.3d 525

Mother (Tisci) sued father (Smith) for custody and child support for child K.S.; temporary orders and a hearing before a magistrate followed.
At the June 22, 2015 hearing the parties stipulated in open court to multiple terms, including father paying child support retroactive to birth and sharing extracurricular costs 50/50; those stipulations were later filed in writing (showing a $326/month support figure and a $1,000 credit to Smith).
Remaining contested issues at the hearing were parenting time and Smith’s motion to show cause for alleged noncompliance with temporary transportation/visitation orders.
The magistrate awarded the stipulated child support, denied the show-cause motion, and set a parenting-time schedule giving Smith alternating Thursday–Sunday time (ending 7:00 a.m. Sunday) and weekly Thursday–Friday time.
The trial court adopted the stipulations, adjusted child support to the written $326 amount (crediting $1,000), rejected Tisci’s request to treat daycare as a separate expense outside the stipulated support, and slightly modified summer parenting time. Tisci appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court erred by not separately awarding daycare expenses in addition to the stipulated child support	Tisci: daycare costs should be awarded separately (arguing they fall within "extracurricular/enrichment" or are not covered fully by the stipulated amount)	Smith: parties stipulated to a retroactive monthly support amount that includes child-care components and he had paid $1,000 credit	Court: upheld stipulation; daycare is part of child-support calculation and the parties knowingly agreed to the stipulated amount, so no separate award; future modification may be sought if circumstances change
Whether parenting time was improperly allocated to Smith on days he worked (when mother could parent)	Tisci: awarding time when Smith worked (Saturdays) is not in child’s best interest because he couldn’t exercise time; mother was available	Smith: testified caretakers (parents/siblings) would supervise during his work shift and he would spend time with child when not working; schedule aligns with his days off	Court: no abuse of discretion; testimony supported that child care and contact would occur during father’s workdays and schedule was appropriate

Booth v. Booth, 44 Ohio St.3d 142 (1989) (domestic-relations child-support and allocation decisions are reviewed for abuse of discretion)
Blakemore v. Blakemore, 5 Ohio St.3d 217 (1983) (defines abuse of discretion as more than error of law or judgment)