Trent v. Taylor, 2017 Ohio 7189

Tommy Trent and Jill Taylor, never married, share three minor children; long history of Trent's substance abuse and prior protective orders against him.
Parties entered a September 9, 2014 agreed judgment providing a graduated, drug-test–contingent parenting-time plan (90-day urine program, supervised visitation steps).
Trent repeatedly failed to complete the agreed drug-testing program and was expelled from a supervised-visitation center; reunification counseling followed under court orders.
Magistrate issued a temporary order (Oct. 7, 2016) granting limited supervised visitation, hair-follicle and urine testing, reunification counseling with a new counselor, Skype/phone contacts, and cost-splitting for certain testing and medical expenses.
Taylor objected (pro se) to the magistrate order; trial court treated her filing as a motion to set aside, held a hearing, and (Jan. 12, 2017) vacated the magistrate’s temporary visitation order, awarded Taylor $4,000 in attorney fees, allocated 75%/25% responsibility for children’s uninsured medical costs (Trent/Taylor), and ordered continued reunification counseling per the therapist’s recommendations.
Trial court found Trent had not shown the requisite sustained sobriety, relied on the therapist and GAL recommendations, and declined to impose the magistrate’s supervised-visitation plan (no current supervised-visitation order exists; reunification path remains if Trent follows therapist recommendations).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial court erred by denying Trent any parenting time	Court wrongly blocked parenting time; abuse of discretion	Trial court properly required compliance with agreed drug-testing and therapist recommendations before supervised visits	Affirmed — no abuse: court required adherence to agreed orders and therapist recommendations; path to reunification remains
Whether attorney-fee award to Taylor was improper	Fee award unsupported by affidavit/evidence of rates and incomes	Fees were equitable given protracted litigation caused by Trent and the insurance-card dispute; income disparity	Affirmed — trial court reasonably exercised discretion under Juv.R.40(B) and considered conduct/income disparity
Whether ordering Trent to pay 75% of uninsured medical expenses was error	Taylor did not show unpaid medical expenses; statutory support-order requirements unmet	Children were removed from prior public coverage when added to Trent’s wife’s plan, causing Taylor out-of-pocket expenses; no support order exists	Affirmed — allocation was within discretion given circumstances and income disparity
Whether trial court abused discretion by considering Taylor’s untimely objections	Taylor’s objections were untimely and should have been stricken	Taylor proceeded pro se and court excused procedural defect to decide on merits	Affirmed — court permissibly converted/treated filing as motion to set aside and heard merits; no abuse

Blakemore v. Blakemore, 5 Ohio St.3d 217 (1983) (defines abuse of discretion standard)
Thomas v. Cleveland, 176 Ohio App.3d 401 (2008) (discusses when a reviewing court finds an abuse of discretion)