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72 Ohio App. 3d 417

594 N.E.2d 1008

Brown v. Denny

Ohio Court of Appeals

Decided February 8, 1991

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Ohio Court of Appeals · decided 1991-02-08

Good law ✅— No negative treatment on recordhow we know

Decided 1991-02-08

How this case has been cited

Cited by 33 later decisions — most recently May 2025 · most notably 97 Ohio App. 3d 693 - Tschantz v. Ferguson (1994), 134 Md. App. 51 - Lapides v. Trabbic (2000)

21 state decisions

1401991200020102020decided

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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*424 Wilson, Judge,

¶1 concurring in judgment.

¶2 I agree with the majority in its disposition of the first and second assignment of error for the reasons stated. In my view, a claim for tortious interference with the visitation rights of a noncustodial parent should also be denied based upon “public policy and fear that it would encourage a multitude of claims for petty infractions.” Kark, Domestic Torts: Family Violence, Conflict and Sexual Abuse (1989) 221, Section 5.17.

¶3 The Dennys aided, abetted, and subsidized their daughter in denying the plaintiff a “possessory interest” in his children. However, this activity is not the basis of a civil action under R.C. 2307.50 unless the minor is a victim of a “child stealing crime.” In my view, a person who aids a custodial parent in depriving a noncustodial parent of a possessory interest in his children has not committed a child stealing crime.

¶4 I would overrule the third assignment of error.

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