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3 Ohio App. 3d 421

445 N.E.2d 1125

Venable v. Venable

Ohio Court of Appeals

Decided July 9, 1981

Ohio Court of Appeals · decided 1981-07-09

Good law ✅— No negative treatment on recordhow we know

Decided 1981-07-09

How this case has been cited

Cited by 16 later decisions — most recently November 2025

16 state decisions

7019811990200020102020decided

Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.

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Day, J.,

¶1 concurring. I concur in the judgment but add these few words to explain my understanding of the legal effect of the decision.

¶2 First, the best interest of the child is the prime consideration in any custody case.

¶3 Second, preference and election, where applicable, are important considerations in the custody decision but are not controlling per se.

¶4 Third, to the degree the trial court applied preference and election on a per se or compelling basis, it was in error.

¶5 Finally, I would not characterize appellant’s counsel’s argument as “hollow and narrow-minded.” To me, it seems more accurate to call it ingenious but mistaken.

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