The Ohio Court of Appeals has upheld a juvenile court's decision regarding the custody of D.J., an eight-year-old boy. The court ruled that D.J.'s father, J.J., will retain legal custody of the child while granting the mother, D.W.-S., some additional visitation rights. This ruling is significant for families navigating custody disputes, as it highlights the court's focus on the child's best interests and the necessity of demonstrating a change in circumstances for custody modifications.

The case, filed under docket number 116337, began when D.W.-S. appealed a juvenile court's earlier decision that granted J.J. sole legal custody of D.J. The initial ruling also allowed D.W.-S. only supervised visitation every other Saturday. D.W.-S. sought to modify this arrangement to a 50/50 shared parenting plan, arguing that her circumstances had changed and that she was ready for more involvement in her child's life.

In her appeal, D.W.-S. claimed that the juvenile court had abused its discretion in several ways, including by not recognizing her requests for shared parenting and by imposing psychological evaluations on her without similar requirements for J.J. The case was heard by Judge Lisa B. Forbes, who presided over the court's decision.

Background

The dispute in this case centers around the custody and parenting time of D.J., who was placed in the sole legal custody of his father, J.J., by the juvenile court in September 2023. At that time, D.W.-S. was granted limited supervised visitation. The court's decision was made after concerns about D.W.-S.'s mental health and her ability to provide a stable environment for D.J. emerged.

On December 2, 2024, D.W.-S. filed a motion to modify the custody arrangement, seeking a more equitable 50/50 shared parenting plan. A hearing was held on October 27, 2025, where both parents provided testimony regarding their parenting abilities and the child's well-being. The court also heard from a guardian ad litem, who recommended that J.J. retain legal custody of D.J. The guardian noted that D.J. was thriving under his father's care.

The Ruling

On March 9, 2026, the juvenile court issued a journal entry sustaining some of D.W.-S.'s objections but ultimately upholding the decision that J.J. would maintain legal custody of D.J. The court found that there had not been a substantial change in the child's circumstances since the initial ruling. Judge Forbes stated, "The communication between the parties is not healthy," indicating that the parents had difficulty cooperating regarding D.J.'s upbringing.

The court did, however, expand D.W.-S.'s visitation rights, allowing her to spend more time with D.J. on weekends and Thursdays. Additionally, it mandated that D.W.-S. undergo a psychological evaluation, while J.J. was not subjected to similar requirements. The court justified this by noting that D.W.-S.'s mental health had previously affected her parenting ability, while J.J.'s issues did not appear to interfere with his parenting.

Impact

This ruling has important implications for custody disputes in Ohio. It emphasizes that parents seeking to modify custody arrangements must demonstrate a change in circumstances and that the court will prioritize the child's best interests. The decision also illustrates the court's willingness to impose conditions on one parent based on their past behavior and mental health, which can affect custody decisions.

As the court noted, the absence of a substantial change in circumstances can support maintaining the current custody arrangement. In this case, the court found that D.J. was doing well under his father's care, which contributed to its decision to uphold the existing custody order. This ruling may serve as a precedent for similar cases in the future.

What's Next

D.W.-S. has the option to appeal the court's decision, but the ruling currently stands. There are no related cases pending at this time. The court's decision highlights the ongoing challenges faced by parents in custody disputes and the importance of demonstrating a commitment to the child's well-being.