R.C. 3109.04(E)(1)(A) Interpretation
In Fisher v. Hasenjager (2007), 116 Ohio St.3d 53, 2007 Ohio 5589, 876 N.E.2d 546, the Ohio Supreme Court addressed R.C. 3109.04(E)(1)(a) and determined that modification of the designation of residential parent and legal custodian of a child requires a determination that a "change in circumstances" has occurred, as well as a finding that the modification is in the best interest of the child. Id. at syllabus.