Background
April Bott Moore and Robert Dean Moore divorced after agreeing to a shared-parenting plan for their child. The plan required them to use a qualified parenting coordinator for post-decree dispute resolution. The domestic-relations court repeatedly appointed or reappointed parenting coordinators as the parties continued to disagree over shared-parenting issues.
After the coordinator’s two-year appointment neared expiration, Robert moved in July 2024 to reappoint her. April initially agreed to a one-year extension but later opposed it, arguing that the coordinator had not interviewed the child or the child’s educators, favored Robert’s concerns, and had engaged in an improper substantive ex parte communication with a magistrate. The trial court reappointed the coordinator on April 8, 2025, finding April’s allegations unsubstantiated or insufficient to outweigh the coordinator’s familiarity with the case.
The Court’s Holding
The Tenth District affirmed. It first held that the reappointment order was a final, appealable order under R.C. 2505.02(B)(4). Parenting coordination is a provisional remedy because it is an ancillary proceeding that helps implement parental-rights orders, and the post-decree order conclusively resolved the parenting-coordination issue without a later final judgment through which April could obtain meaningful review.
The trial court retained authority to decide Robert’s pending reappointment motion after entering the amended divorce decree and while that decree was on appeal. Parenting coordination remained a separate, continuing enforcement mechanism tied to the shared-parenting decree; it was not implicitly denied or merged out of existence by the divorce judgment. The appellate court also found no abuse of discretion in reappointing the same coordinator. The record supported the trial court’s findings that the alleged ex parte communication was not established, interviews of the child and educators were authorized rather than required, and April had not shown impermissible bias or other misconduct.
Key Takeaways
- A post-decree order appointing or reappointing a parenting coordinator is appealable as an order granting a provisional remedy.
- Parenting coordination is an ancillary enforcement process that can continue after a final divorce decree and during an appeal, so long as it does not conflict with the appellate court’s jurisdiction.
- A party challenging a coordinator’s reappointment must show more than unsubstantiated allegations or disagreement with the coordinator’s handling of disputes to establish an abuse of discretion.
Why It Matters
The decision adopts the view that parenting-coordinator appointments are immediately reviewable in post-decree domestic-relations cases, while confirming that those appointments do not disappear merely because the underlying divorce case reaches a final judgment.
For family-law practitioners, the case underscores the trial court’s broad discretion in selecting a coordinator and the importance of developing concrete record evidence of rule violations, bias, or other grounds for replacement.