Ohio Revised Code

Ohio Rev. Code § 3109.51 (2026)

Definitions

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As used in sections 3109.52 to 3109.80 of the Revised Code:

(A) "Child" means a person under eighteen years of age.

(B) "Custodian" means an individual with legal custody of a child.

(C) "Guardian" means an individual granted authority by a probate court pursuant to Chapter 2111. of the Revised Code to exercise parental rights over a child to the extent provided in the court's order and subject to the residual parental rights, privileges, and responsibilities of the child's parents.

(D) "Legal custody" and "residual parental rights, privileges, and responsibilities" have the same meanings as in section 2151.011 of the Revised Code.

Notes of Decisions
Cited in 12 cases (2 in the last 5 years), 1996–2023 · leading case: I.R. v. D.R., 2023-Ohio-1427.
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I.R. v. D.R., 2023-Ohio-1427. · cites it 2× “Father has failed to differentiate between the two or present this Court with an argument specifically addressed to the factors contained in R.C. 3109.51(D). {¶34} This Court declines to engage in an exhaustive review of the best interest factors outlined in R.”
In re K.P.R., 966 N.E.2d 952 (Ohio Ct. App. 12th Dist. 2011). “2: {¶ 28} “The trial court erred in granting parenting time pursuant to Ohio Revised Code § 3109.51(d).” {¶ 29} Assignment of Error No.”
Green v. Quint-Green, 2020-Ohio-4141. · cites it 10× “04, instead of R.C. 3109.51, nor does it explain what evidence indicated that supervised visitation was necessary to keep the child safe.”
Doughty v. Doughty, 2019-Ohio-974. “12(A) and/or R.C. 3109.51(B)(1). Ferguson filed an amended motion on March 28, 2017 to correct procedural issues.”
In re L.K.P., 2017-Ohio-500. “{¶11} “The General Assembly has authorized grandparent visitation in three situations: (1) in divorce, dissolution, legal separation, or annulment proceedings (R.C. 3109.51); (2) where the parent of the child is deceased (R.”
McNeal v. Mahon, 2016-Ohio-5373. “{¶ 22} "Upon the filing of [a] notice of intent to relocate as provided in R.C. 3109.51(G)(1), the trial court must first determine whether any court orders, such as an agreed divorce decree, separation agreement, or shared parenting plan, limit the ability of the parent filing…”
Emigh v. Swiger, 2016-Ohio-272. “04(F) for the reallocation of parental rights and responsibilities are the same as or similar to the factors for visitation modification under R.C. 3109.51(D), some of them are unique to the latter statute.”
Clemens v. Clemens, 2021-Ohio-3094. “{¶54} Husband argues the trial court committed error in issuing parenting time for Husband.”
Davis v. Davis, 685 N.E.2d 1292 (Ohio Ct. App. 7th Dist. 1996). “Appellant’s second assignment of error alleges: “The trial court abused its discretion by not awarding plaintiff-appellant Debbie Davis attorney fees and costs under R.C. 3109.51(K) when defendantappellee Jeffrey Davis admitted at the hearing to repeated contempts of court,…”
Tipton v. Tipton, 2013-Ohio-4901. “” The trial court did not set forth a specific schedule as required by R.C. 3109.51(A), did not reference Local R.”
Ghani v. Greenfield, 2018-Ohio-3259. “011(B)(21); see also R.C. 3109.51(D) (" 'Legal custody' and 'residual parental rights, privileges, and responsibilities' have the same meanings as in section 2151.”
Richardson v. Richardson, Unpublished Decision (1-19-2000), No. 99CA28 (Ohio Ct. App. 5th Dist. Jan. 19, 2000). “* * * R.C. 3109.51 [3109.05.1](C) provides, "If the court interviews any child * * *, the interview shall be conducted in chambers, and no person other than the child, the child's attorney, the judge, and any necessary court personnel, and, in the judge's discretion, the…”
Ohio Rev. Code § 3109.51(A): 1 case
Tipton v. Tipton, 2013-Ohio-4901. “” The trial court did not set forth a specific schedule as required by R.C. 3109.51(A), did not reference Local R.”
Ohio Rev. Code § 3109.51(B)(1): 1 case
Doughty v. Doughty, 2019-Ohio-974. “12(A) and/or R.C. 3109.51(B)(1). Ferguson filed an amended motion on March 28, 2017 to correct procedural issues.”
Ohio Rev. Code § 3109.51(D): 4 cases
I.R. v. D.R., 2023-Ohio-1427. “Father has failed to differentiate between the two or present this Court with an argument specifically addressed to the factors contained in R.C. 3109.51(D). {¶34} This Court declines to engage in an exhaustive review of the best interest factors outlined in R.”
Green v. Quint-Green, 2020-Ohio-4141. “04, instead of R.C. 3109.51, nor does it explain what evidence indicated that supervised visitation was necessary to keep the child safe.”
Emigh v. Swiger, 2016-Ohio-272. “04(F) for the reallocation of parental rights and responsibilities are the same as or similar to the factors for visitation modification under R.C. 3109.51(D), some of them are unique to the latter statute.”
Ghani v. Greenfield, 2018-Ohio-3259. “011(B)(21); see also R.C. 3109.51(D) (" 'Legal custody' and 'residual parental rights, privileges, and responsibilities' have the same meanings as in section 2151.”
Ohio Rev. Code § 3109.51(D)(1): 1 case
Green v. Quint-Green, 2020-Ohio-4141. “04, instead of R.C. 3109.51, nor does it explain what evidence indicated that supervised visitation was necessary to keep the child safe.”
Ohio Rev. Code § 3109.51(G)(1): 1 case
McNeal v. Mahon, 2016-Ohio-5373. “{¶ 22} "Upon the filing of [a] notice of intent to relocate as provided in R.C. 3109.51(G)(1), the trial court must first determine whether any court orders, such as an agreed divorce decree, separation agreement, or shared parenting plan, limit the ability of the parent filing…”
Ohio Rev. Code § 3109.51(K): 1 case
Davis v. Davis, 685 N.E.2d 1292 (Ohio Ct. App. 7th Dist. 1996). “Appellant’s second assignment of error alleges: “The trial court abused its discretion by not awarding plaintiff-appellant Debbie Davis attorney fees and costs under R.C. 3109.51(K) when defendantappellee Jeffrey Davis admitted at the hearing to repeated contempts of court,…”
Ohio Rev. Code § 3109.51(d): 1 case
In re K.P.R., 966 N.E.2d 952 (Ohio Ct. App. 12th Dist. 2011). “2: {¶ 28} “The trial court erred in granting parenting time pursuant to Ohio Revised Code § 3109.51(d).” {¶ 29} Assignment of Error No.”
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