Court Filings

The Ohio Tenth District Court of Appeals affirmed the Franklin County trial court's July 21, 2025 judgment denying appellant Christina Bushong's Civ.R. 60(B) motion for relief from judgment. The court held that the parties' November 17, 2023 memorandum of agreement did not itself dismiss the case because no journalized dismissal entry was filed, so the trial court retained jurisdiction to resolve the child-support issues. The court also found appellant failed to timely appeal the June 24, 2025 judgment adopting a magistrate's contempt decision, so the appellate court lacked jurisdiction to review that portion of the proceedings.

The Appellate Division affirmed the Family Part's April 4, 2025 order reinstating and enforcing child support arrears owed by Shawn J. Harris to his ex-wife, Della M. Bournes. The court found New Jersey properly registered and enforced a Texas child-support order under the Uniform Interstate Family Support Act (UIFSA), and that a November/October 2024 administrative USSO that closed enforcement improperly vacated arrears. Because the anti-retroactivity statute does not bar cancelling or reinstating arrears tied to a child's emancipation and Harris never obtained a retroactive reduction by court motion, the judge correctly reinstated arrears and denied Harris's cross-motion.

The Appellate Division, First Department affirmed Family Court orders that found respondent mother neglected her eldest child and derivatively neglected two other children. The court concluded, based on a preponderance of the evidence, that the mother choked the eldest child, pulled and ripped the child's shirt, and caused scratches; the child’s out-of-court statement was corroborated by a caseworker’s observation and photographs. The court also found the mother committed acts of domestic violence during the same incident and that the other children were present, supporting derivative neglect because the mother’s conduct created a substantial risk of harm.

The Appellate Division reviewed Family Court's partial denial of a mother's petition to remove a prohibition on her partner's contact with her child. The court found the mother's sobriety constituted a sufficient change in circumstances to permit a full best-interests review, but concluded Family Court reasonably kept the no-contact provision in place because the child remained affected by the mother's past alcohol-related incidents and expressed reluctance to see the partner. The Appellate Division modified the order to allow the mother to seek removal of the prohibition after six months without proving a new change, and otherwise affirmed.

The Appellate Division affirmed Family Court's July 2, 2024 order modifying custody and parenting time for a child born in 2011. Family Court awarded primary physical custody to the father, granted the grandparents limited monthly visitation plus additional holiday and summer time, and denied the mother's request to convert supervised parenting time to unsupervised time. The appellate court found the visitation schedule supported by the child's best interests given travel burdens and the child's anxiety, and upheld supervised parenting time because the mother had an inconsistent parenting history and was still on a high methadone dosage without other supports.

The Appellate Division (Third Department) affirmed Family Court's March 12, 2025 order terminating the mother's parental rights after adjudicating the child permanently neglected. The child, born in 2019, has autism and developmental delays and has been in foster care since May 2023 following the mother's arrest for driving while intoxicated with the child. The court found the mother repeatedly failed to meaningfully engage in or complete substance abuse treatment, did not make significant progress toward reunification, and that termination — allowing adoption by foster parents who provided stable, therapeutic care — served the child's best interests.

The Appellate Division, Third Department affirmed Family Court's March 15, 2023 order awarding the child's maternal grandmother sole legal and physical custody. The father appealed only arguing the judge abandoned neutrality and acted as an advocate for the grandmother. The appellate court found the issue unpreserved because the father did not raise it below, and in any event the record shows the judge's active questioning was appropriate to assist a pro se petitioner and to elicit relevant information. The court concluded there was no judicial bias and affirmed the custody order.

The Tenth Court of Appeals reviewed Father's appeal of a trial court order terminating his parental rights to four children. Counsel filed an Anders brief concluding the appeal is frivolous, and Father submitted a pro se response. The appellate court conducted a full review of the record, found sufficient evidence to support the trial court’s findings that Father violated Family Code §161.001(b)(1)(D) and (E) and that termination was in the children’s best interest, and affirmed the termination order. The court denied counsel’s motions to withdraw because they did not show independent good cause under Texas law.

The Tenth Appellate District of Texas affirmed the trial court’s dismissal of Appellant’s bill of review challenging a July 26, 2022 order that terminated his parental rights to A.A.C.C. The Department moved for traditional summary judgment, arguing a six-month statutory bar under Texas Family Code §161.211(a) prevents collateral or direct attacks on such termination orders. Appellant did not file any response to the summary judgment motion. The court held the Department met its burden by showing the termination was under §161.002(b) and the bill of review was filed well after the six-month deadline, so the petition was time-barred.

The Texas Ninth Court of Appeals affirmed a trial court order terminating both parents’ rights to infant Ivy after a jury found, by clear and convincing evidence, statutory grounds D, E, and N and that termination was in the child’s best interest. The Department of Family and Protective Services removed Ivy after she arrived at the hospital with a fractured femur, liver laceration, and bruising; testimony and medical opinions raised serious abuse concerns and showed parental instability and untreated mental-health issues. The court also upheld appointment of the Department as managing conservator and denied Mother’s mistrial claim about an improper juror communication.

The Fifth District Court of Appeal reviewed an appeal by Christopher Shootes from a Duval County circuit court domestic relations matter. The appellate court, in a short per curiam decision, affirmed the lower court's ruling and cited Florida Rule of Appellate Procedure 9.315(a) as the basis for affirmance. No written opinion or extended reasoning was provided; the panel issued a summary affirmance and noted that the decision is not final until any permitted motions for rehearing are resolved.

The Appellate Division affirmed a Family Court order modifying custody and access in related Family Court Act articles 6 and 8 proceedings. After a hearing and an in-camera interview with the child, the Family Court found the father committed assault in the third degree and menacing in the second and third degrees against the child, awarded the mother final decision-making authority, limited the father's parenting time to therapeutic supervised access, denied the father's cross-petition to change custody, and issued a two-year order of protection for the child. The appellate court found no deprivation of the father's right to counsel and found no reversible error.

The Appellate Division, Second Department affirmed a Family Court order resolving where a child should attend school. The parents, who share joint legal custody and alternate weekly parenting time, could not agree on school district enrollment. After a hearing, Family Court granted the father's petition to enroll the child in the South Huntington Union Free School District and denied the mother's petition to enroll the child in the Hauppauge Union Free School District. The appellate court found the Family Court's best-interests determination had a sound and substantial basis, citing the child's benefit from a diverse environment and likely residential stability with the father.

The Appellate Division, Second Department affirmed an amended Family Court order finding the mother neglected one child by inflicting excessive corporal punishment and derivatively neglected the other child. Appeals challenging the release of the children to the father and the dismissal of the mother's custody and visitation petitions were dismissed as academic because subsequent Virginia proceedings and the expiration of supervision rendered those parts moot. The court upheld the directive that the mother submit to a comprehensive mental health evaluation, finding it to be in the children's best interests and supported by the evidence and credibility findings below.

The Appellate Division affirmed a Family Court order granting joint custody of a child to the father and the maternal aunt after a combined permanency and fact-finding hearing. The mother appealed, arguing the court failed to ensure she knowingly waived her right to counsel when her appointed lawyer was relieved. The court found that although the Family Court did not conduct the required detailed inquiry at the time of counsel’s withdrawal, the mother’s pattern of conduct — frequent failures to appear, multiple successive attorneys, and delays — supported a finding she forfeited her right to assigned counsel, and the evidence would not have changed the outcome.

The Appellate Division affirmed Family Court orders awarding sole residential and legal custody of a child (born 2013) to the child's paternal aunt and denying the mother's custody petition. The aunt had cared for the child continuously since February 2018 after the mother was arrested and incarcerated and had filed for custody in October 2018; the mother filed her own custody petition in 2021. The court found the aunt proved "extraordinary circumstances" that overcame the parent's superior right and, after considering the child's best interests, concluded the aunt was better able to provide stability and meet the child's needs.

The Second District Court of Appeal reviewed a dependency case involving children E.W., C.M., and C.C. with J.R.B. as the appellant and the Department of Children and Families and the Statewide Guardian ad Litem Office as appellees. The appellate court issued a short per curiam decision and affirmed the lower court's ruling. No additional reasoning or changes to the trial court's orders were provided in the published opinion; the panel concurred and the judgment stands as affirmed.

The Fifth District Court of Appeal reviewed a nonfinal appeal from the Circuit Court for Clay County in a family-law case between Michelle Lany Yoakum (appellant) and William Lee Tschumy, Jr. (appellee). The appellate panel issued a per curiam decision on April 28, 2026, summarily affirming the lower court's order. The opinion is brief and cites no reasoning or authorities; the court simply affirmed the trial court's ruling and noted the decision is not final until any timely authorized motion is resolved.

The Sixth District Court of Appeal affirmed the lower court's decision in a Lee County family-law case. Appellant Stacy James (pro se) appealed the circuit court's ruling below; the appellate court issued a per curiam opinion on April 28, 2026, simply stating "AFFIRMED." No additional reasoning or discussion is provided in the opinion, and the panel's judges concurred. Both parties appeared pro se in the appeal. The mandate will issue after the rehearing period expires if no timely motion is filed.

The Warren County Juvenile Court granted Warren County Children Services (WCCS) permanent custody of nine-year-old S.F., rather than returning her to the legal custody of her 74-year-old paternal grandmother. WCCS sought permanent custody after S.F. wandered away from grandmother’s home and exhibited severe behavioral and mental-health problems requiring specialized treatment. The juvenile court found grandmother medically frail, lacking stamina and knowledge to meet S.F.'s needs, and unable to provide the legally secure, specialized care S.F. requires. The appellate court affirmed, concluding the finding was supported by the weight of the evidence and was in S.F.'s best interest.

The Ohio Court of Appeals (Twelfth District) affirmed the probate court's ruling that the child's biological mother must give consent before the child may be adopted by the maternal grandmother. The probate court had found the mother had justifiable cause for failing to provide financial support during the one-year look-back period prior to the adoption petition, and the appellate court held that finding was supported by competent, credible evidence and was not against the manifest weight of the evidence. The court emphasized that adoption terminates parental rights and exceptions to consent must be strictly construed, and it concluded the mother reasonably believed her financial help was unnecessary because the petitioners provided fully for the child and never sought parental support.

The Court of Appeals of Georgia affirmed the juvenile court’s order awarding permanent guardianship of infant A.A. to his paternal grandmother. The Department of Family and Children Services had petitioned for guardianship after dependency proceedings placed the children with the grandparents. The appellate court reviewed the record in the light most favorable to the juvenile court, found sufficient evidence supporting that reunification efforts would be detrimental and that guardianship served the child’s best interests, and rejected the mother’s procedural and legal challenges as either unpreserved, moot, or without merit.

The Montgomery County Court of Appeals affirmed the juvenile court’s decision to grant legal custody of six-year-old P.W. to her father. The child had been adjudicated neglected and dependent after the mother’s arrest and unsafe home conditions; the mother later entered residential drug treatment and had interrupted in-person contact. The father completed assessments and a home study, developed a consistent visitation schedule, and showed stability. The appellate court found the juvenile court reasonably applied Ohio’s best-interest factors and concluded legal custody to father was supported by the preponderance of the evidence.

The Ohio Court of Appeals affirmed the juvenile court’s judgments granting permanent custody of three children (C.P., M.R., and C.R.) to the Montgomery County Department of Jobs and Family Services – Children Services Division (MCCS). MCCS had removed the children for neglect and dependency, obtained temporary custody, and later moved for permanent custody. The court found by clear and convincing evidence that reunification with the mother was unlikely in the foreseeable future and that awarding permanent custody to MCCS was in the children’s best interests, given the children’s behavioral needs, the mother’s inconsistent engagement with services and visits, housing and stability concerns, and exposure to a known substance user.

The Appellate Division affirmed a divorce judgment, modifying it to reduce the required life insurance the husband must carry from $750,000 to an amount equal to the remaining unpaid maintenance and allowing a declining term policy. The court upheld the equitable distribution, the sale of marital real estate, the maintenance award (including using the statutory income cap), and the attorney-fee award, rejecting claims of dissipation and insufficient property valuation. The cross-appeal succeeded only on the life-insurance security amount, which the court held should track the unpaid maintenance balance and decline as payments are made.

The Appellate Division, Fourth Department affirmed Family Court's order continuing custody of the child with Monroe County Department of Human Services. The mother had sought return of her child under Family Court Act § 1028 after a temporary removal. The court found petitioner proved that returning the child would present an imminent risk to the child's life or health because the mother suffers from untreated, severe mental health conditions, experiences frequent violent visions that sometimes include the child, lacks insight, does not take medication or seek therapy, and engages in unsafe behavior tied to those visions. The appellate court found a sound and substantial basis in the record for that determination.

The Appellate Division, Fourth Department affirmed a Family Court order that granted the petitioner's written objection to a support magistrate's October 7, 2024 order in a Family Court child support proceeding. The appeal was taken by the respondent from the Family Court's November 27, 2024 order. The appellate court unanimously affirmed without costs, signaling it found no reversible error in the Family Court's disposition of the objection to the support magistrate's ruling.

The Appellate Division, Fourth Department affirmed Family Court's March 17, 2025 order in a child-protective proceeding under Family Court Act article 10, which had found that respondent Thomas M. neglected the child Aleena M. The appeal challenged that neglect determination; the appellate court issued a short per curiam affirmance, adopting the reasoning set out in its separate memorandum in Matter of Akeem M. (Thomas M.). The court thus left undisturbed the Family Court's findings and disposition holding Thomas M. neglectful.

The Appellate Division, Fourth Department affirmed a Family Court order that found Thomas M. neglected the child Ahmilia M. This appeal challenged the Family Court’s neglect determination in a proceeding brought by the Onondaga County Department of Children and Family Services under Family Court Act article 10. The appellate court relied on the same reasoning and memorandum it used in a companion case (Matter of Akeem M. (Thomas M.)) and concluded there were no reversible errors, so the Family Court’s ruling stands and costs were denied.

The Appellate Division, Fourth Department affirmed Family Court's order finding Heather H. neglected her child and placing her under the supervision of the Wayne County Department of Social Services. The appeal challenged the fact-finding that the mother's mental illness and illicit drug use caused neglect, but the appellate court held petitioner proved neglect by a preponderance of the evidence. The court relied on testimony and records showing the mother experienced delusions and paranoid behavior that placed the child's physical, mental, or emotional condition in imminent danger of impairment, and affirmed the dispositional supervision order.