Sistek v. Grendence

In Sistek v. Grendence, Lake App. No. 2005-L-212, 2006 Ohio 4169. the Eleventh District Court of Appeals explained that "in issuing a civil protection order, the trial court may add restrictions, provided they are "equitable and fair." citing R.C. 3113.31(E)(1)(h). "While R.C. 3113.31 affords trial courts discretion in imposing restrictions corresponding to a civil protection order, this discretion is not limitless." Sistek, supra; citing Maag v. Maag (Mar. 28, 2002), Wyandot App. No. 16-01-16, 2002 Ohio 1401. As further noted by the Sistek court, "in determining the reasonableness of a restriction of a civil protection order, the Third Appellate District has adopted a standard similar to that used in determining whether a condition of probation is unduly restrictive. Id. Thus, "restrictions must bear a sufficient nexus to the conduct that the trial court is attempting to prevent." Id.