Davis v. Flickinger

R.C. 3109.04 requires a finding of a “change in circumstances.” Such a determination when made by a trial judge should not be disturbed, absent an abuse of discretion. In determining whether a change in circumstances has occurred so as to warrant a change in custody, a trial judge, as the trier of fact, must be given wide latitude to consider all issues which support such a change, including a change in circumstances because of a child’s age and *417consequent needs, as well as increased hostility by one parent (and that parent’s spouse) which frustrates cooperation between the parties on…