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Braatz v. Braatz
Citations: 81 Ohio St. 3d 1418; 688 N.E.2d 1045; 1998 Ohio LEXIS 387Docket: 97-2566
Court: Ohio Supreme Court; January 20, 1998; Ohio; State Supreme Court
A conflict has been identified regarding the modification of visitation orders, specifically whether a moving party is required to show a change of circumstances for a trial court to modify its prior judgment. The legal frameworks in question are R.C. 3109.04 and R.C. 3109.051. The relevant conflict case cited is **Jacobs v. Jacobs** (1995), with dissent from Judge Sweeney. Additionally, the court must address whether a trial court is obligated to provide findings of fact and conclusions of law upon a timely request in visitation modification proceedings, referencing the conflict case **In re Thrush** (1988), with dissent from Judges Sweeney, Cook, and Lundberg Stratton. The parties are instructed to prepare briefs on both issues as outlined in the court of appeals’ Journal Entry dated November 14, 1997.