Braatz v. Braatz

Mahoning App. No. 95 C.A. 260. On review of order certifying a conflict. The court determines that a conflict exists; the parties are to brief the issue stated at page 2 of the court of appeals’ Journal Entry filed November 14,1997:

“ ‘Whether a moving party must demonstrate a change of circumstances for a trial court to modify its prior judgment regarding visitation?’

“At issue is whether R.C. 3109.04 or R.C. 3109.051 is applicable to a modification of visitation.”

The conflict case is Jacobs v. Jacobs (1995), 102 Ohio App.3d 568, 657 N.E.2d 580.

The parties are also to brief the issue stated at…