Court Filings

The Eighth District Court of Appeals reviewed a juvenile court’s orders on parenting time, modification of a shared-parenting plan, and a contempt finding. The appellate court affirmed most rulings: it upheld the denial of Mother’s motion to terminate the shared-parenting agreement and the juvenile court’s decision not to further modify parenting time based on the record and the guardian ad litem’s findings. However, the court reversed the contempt finding against Mother because she established a reasonable, good-faith basis for withholding Father’s parenting time due to concerns about his housing, utilities, and alleged substance use and she promptly sought court intervention. The remainder of the juvenile court’s orders were left intact.

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 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 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 Ohio Eighth District Court of Appeals affirmed the juvenile court’s grant of permanent custody of 10-year-old C.F. to the Cuyahoga County Division of Children and Family Services (CCDCFS), terminating the parental rights of L.Y. (mother) and D.F. (father). The child had been repeatedly removed for concerns including domestic violence, parental substance use, and unmet mental-health and educational needs. The court held that statutory grounds for permanent custody were met and that permanent custody best served the child’s interests because C.F. was thriving in his caregiver J.F.’s home while Mother had not remedied the conditions that led to removal or demonstrated reliable sobriety or engagement with services.

The Ohio Fifth District Court of Appeals affirmed the trial court's October 6, 2025 judgment denying Lynette L. Shidaker’s post-judgment motions seeking to reopen or set aside the May 31, 2023 divorce judgment. The appellate court held the trial court did not abuse its discretion in finding the Civ.R. 60(B) motion untimely despite being filed within one year, concluding Appellant had known of the asserted grounds earlier and offered no sufficient explanation for delay. The court also rejected Civ.R. 60(A) relief for alleged clerical error in spousal-support calculations and found it lacked jurisdiction to review arguments that should have been raised in a timely appeal from the 2023 judgment.

The Tenth District Court of Appeals affirmed the Franklin County trial court’s March 27, 2025 judgment that granted intervenor Kelly Moore’s motion for relief from judgment, ordered genetic testing of the older child (L.M.), and denied plaintiff-appellant Joyce Wilson’s motion for reconsideration. Joyce had sought custody of her two grandchildren and argued the court lacked jurisdiction because a 2010 paternity affidavit for the older child established paternity. The appeals court held that Ohio law (R.C. 3119.962) allows challenge to an acknowledgment of paternity via genetic testing and that the trial court did not abuse its discretion in permitting Moore to intervene despite procedural shortcomings.

The Court of Appeals affirmed the Franklin County domestic relations court’s adoption of a magistrate’s decisions that established paternity, named Jessica L. Jackson sole residential parent and legal custodian of the minor child J.J., granted parenting time to Rajael H. Tyler, and ordered Tyler to pay about $140 per month in child support. Jackson appealed, alleging evidentiary error and perjury at a child-support hearing, but she did not file objections to the magistrate’s decision. The appellate court declined to consider the hearing transcript not before the trial court and found any unobjected-to errors waived absent a showing of plain error, which Jackson did not raise.

The Twelfth District Court of Appeals affirmed the Clermont County Domestic Relations Court's final divorce decree between Kenyata (Wife) and Chris Packer (Husband). The appellate court upheld the trial court's $480,000 valuation of Husband's 75% interest in his company Rod-Techs, finding the valuation supported by competent, credible evidence from experts and rejecting Husband's challenges under the rules for expert testimony. The court also upheld the property equalization payment of about $80,000 to Wife and the spousal support award of $1,520 per month for 106 months, finding the trial court appropriately considered statutory factors.

The Twelfth District Court of Appeals affirmed the juvenile court's denial of Mother's Civ.R. 60(B) motion seeking relief from the adjudication that one child was abused and three were dependent and the related dispositional orders. Mother argued she lacked counsel at critical stages, counsel was ineffective for failing to obtain discovery, the juvenile court failed to comply with procedural safeguards for stipulations, WCCS committed fraud by labeling kinship placements as "foster children" on clothing vouchers, and no safety plan was offered. The appellate court held these claims either were not operative facts warranting an evidentiary hearing, were time-barred or barred by res judicata, and did not satisfy the three-part Civ.R. 60(B) test.

The Ohio Sixth District Court of Appeals affirmed the juvenile court’s decision terminating parental rights and granting permanent custody of three children to the Erie County Department of Job & Family Services. The children were removed after incidents involving domestic violence, unsafe home conditions, and Mother’s criminal charges; Father had minimal contact. The court held the juvenile court properly found the children could not be placed with either parent within a reasonable time, that statutory factors (including failure to remedy conditions, lack of commitment, and a qualifying conviction) were met by clear and convincing evidence, and that permanent custody was in the children’s best interests.

The Ohio Court of Appeals reviewed a final divorce decree after the wife filed for annulment and the husband counterclaimed for divorce. The court reversed the trial court only to the extent it awarded $3,000 in attorney’s fees to the husband, and affirmed the remainder of the decree. The appellate court upheld the trial court’s finding that the wife engaged in financial misconduct — transferring and spending the husband’s premarital funds during the parties’ cohabitation — and approved a $58,827.40 distributive award to compensate the husband and an unequal allocation of marital debts reflecting the wife’s misconduct.

The appellate court affirmed the domestic relations trial court's dismissal of a husband's objections to a civil protection order (DVCPO) as moot. The husband challenged the trial court's finding that two alleged lasting harms — loss of a military housing entitlement and revocation of Global Entry — were not proven collateral consequences of the DVCPO. The appeals court held the husband provided only speculative testimony and no documentation linking the DVCPO to those consequences, so the collateral-consequences exception to mootness did not apply and the trial court did not abuse its discretion.

The Ohio Second District Court of Appeals affirmed the juvenile court’s August 6, 2025 judgment awarding permanent custody of three children to the Clark County Department of Job and Family Services (JFS) and denying the maternal aunt’s request for legal custody. The children were removed after deplorable home conditions and prior dependency adjudications; parents made minimal progress on case plans and mother admitted ongoing drug use. The appellate court found no reversible error in notice to the father, held the mother lacked standing to challenge denial of the aunt’s motion, and concluded the record supported that permanent custody was in the children’s best interest.

The Ninth District Court of Appeals affirmed the juvenile court’s orders placing N.D. in the permanent custody of Summit County Children Services Board (CSB) and placing K.D. in the legal custody of the parents of her friend. The appeals came after contested juvenile proceedings in which the children were adjudicated abused and dependent due to Father’s physical and verbal mistreatment and Mother’s long absence and history of untreated mental illness/substance abuse. The appellate court held CSB proved an alternative statutory ground that the child could not be placed with either parent and found the placements were in the children’s best interests given parental noncompliance and the children’s expressed wishes.

The Fifth District Court of Appeals affirmed the Perry County Domestic Relations Court’s ruling that the pending divorce action abated when the husband (plaintiff) died before any adjudication on the merits. The couple originally filed for dissolution with a separation agreement, the matter was converted to divorce, but no evidentiary hearing or decree occurred before the husband’s death. Because no judicial decision existed that could be journalized after death, the appeals court held the trial court lacked authority to continue the divorce and properly closed the case.

The Ohio Court of Appeals affirmed the juvenile court's grant of permanent custody of John to the Butler County Department of Jobs and Family Services. Mother appealed, arguing the decision was against the manifest weight of the evidence and that her trial counsel was ineffective for not filing a motion to place John with a relative. The court found Mother had abandoned John by failing to maintain contact for more than 90 days and previously lost custody of a sibling, facts that relieved the Agency of reunification obligations and supported a permanent-custody award. The court held Mother's subsequent rehabilitation was insufficient to overcome those statutory factors.

The Ohio appellate court affirmed the juvenile court’s July 3, 2025 order granting Allen County Children Services Board permanent custody of J.H., a child born in August 2023. The Agency originally removed J.H. at birth after the mother tested positive for multiple controlled substances and the child suffered withdrawal; J.H. remained in Agency care for over a year. The court found clear and convincing evidence that reunification was not likely within a reasonable time, that J.H. was bonded to his foster family, and that permanent custody was in the child’s best interest. The mother’s request for a short extension to obtain housing was denied as an abuse of discretion did not occur.

The Ohio Second District Court of Appeals affirmed the Montgomery County trial court's ruling overruling Jonathan Search's objections to a magistrate's decision about parenting time and medical-expense accounting. Father had sought contempt findings, enforcement, and suspension of child support, and filed a self-prepared transcript with his objections. The appellate court held the parenting-time claims moot because the child reached age 18 before the trial court ruled, found no reversible error in the trial court rejecting the uncertified transcript and adopting the magistrate's findings, and determined the dismissal without prejudice of the medical-expense claim left no final order for appeal.

The Second District Court of Appeals affirmed the Miami County Common Pleas Court's adoption of a magistrate’s decision that denied Latrisha McGhee’s post-decree motions concerning child custody, visitation, and related relief, and that suspended her parenting time. The appellate court held the appeal despite McGhee proceeding pro se, finding her appellate brief failed to comply with Ohio Appellate Rule 16 and did not present coherent arguments showing trial-court error. Because meaningful review was impossible, the court affirmed the trial court’s judgment adopting the magistrate’s decision.

The Eighth District Court of Appeals affirmed the Cuyahoga County Domestic Relations Court’s order keeping a one-year civil domestic violence protection order (DVCPO) in place against B.S. (“Stepfather”). Father filed for the DVCPO after Stepfather pushed his son T.H. into a wall twice in November 2024, causing a concussion; CCDCFS substantiated physical abuse and a municipal temporary protection order accompanied a related criminal case. The magistrate found the child-abuse evidence credible and the trial court overruled Stepfather’s objections. The appellate court held the continuance and the DVCPO were not an abuse of discretion and were supported by the record.

The Ohio Tenth District Court of Appeals affirmed the juvenile court’s decision granting permanent custody of two-year-old A.S. to Franklin County Children Services (FCCS), thereby terminating the parental rights of mother L.S. After FCCS filed for permanent custody following nearly two years of involvement because of mother’s mental-health crises, housing instability, and inconsistent engagement with case-plan requirements, the juvenile court found permanent custody was in the child’s best interest. The appeals court held the trial court did not abuse its discretion in denying a day-of-trial continuance and that mother failed to show she received ineffective assistance of counsel or that any alleged deficiency prejudiced her case.

The Ohio Sixth District Court of Appeals affirmed the juvenile court’s September 9, 2025 decision awarding Lucas County Children Services (LCCS) permanent custody of the minor E.D.-P. The child had been adjudicated dependent and temporarily placed with paternal relatives in Texas; LCCS later sought permanent custody. The appellate court held the juvenile court properly found by clear and convincing evidence that R.C. 2151.414(E)(11) applied because Mother had previously had parental rights involuntarily terminated to a sibling and failed to prove she could now provide a legally secure, adequate permanent placement. The court found Mother remained cohabiting and dependent with the child’s father, who showed no engagement in parenting, and the record supported the juvenile court’s findings that reunification was not feasible within a reasonable time.

The First District Court of Appeals affirmed the juvenile court’s denial of a mother’s 2024 motion to regain legal custody of her two children, B.B. and R.W. The juvenile court and magistrate found the mother failed to prove changed circumstances since the 2018 legal-custody disposition to father. The court concluded the evidence (photos, medical summaries, and testimony) did not substantiate abuse or medical neglect by father nor show missed medical care produced harmful consequences sufficient to overcome the statutory presumption of permanency for juvenile-court custody orders.

The Ohio Court of Appeals affirmed a juvenile court judgment awarding permanent custody of infant J.J. to Lucas County Children’s Services (LCCS). The agency filed an original permanent-custody complaint two days after J.J.’s birth based on parents’ extensive prior child-welfare history, unresolved substance-use, housing, and domestic-violence concerns, and prior involuntary termination of parental rights to siblings. The trial court found by clear and convincing evidence that the parents had not rebutted the presumption in R.C. 2151.414(E)(11) and that awarding permanent custody to LCCS was in J.J.’s best interest, so parental rights were terminated.

The Twelfth District Court of Appeals vacated a juvenile-court order that had granted visitation rights to the paternal grandfather because the juvenile court in Madison County lacked subject-matter jurisdiction to decide a grandparent-visitation claim under R.C. 3109.11. The appellate court reviewed statutory text and Ohio Supreme Court precedent establishing that only the common pleas general division has jurisdiction under R.C. 3109.11 and that juvenile courts have only the powers expressly granted by statute. Because Madison County's juvenile division has not been granted the common-pleas division's powers, the visitation judgment was void and therefore vacated.

The Athens County Juvenile Court’s grant of permanent custody of two children to Athens County Children Services was affirmed on appeal. The children had been in agency custody for more than 12 of a consecutive 22-month period. The parents argued the award was against the manifest weight of the evidence and that the agency failed to make reasonable reunification efforts. The court held prior trial-court orders had already found reasonable efforts and that clear-and-convincing evidence supported that permanent custody served the children’s best interests given parental mental-health issues, unresolved interpersonal violence between the parents, the daughter’s refusal to reunify, and the children’s need for stability.

The First District Court of Appeals affirmed the trial court’s adoption of a magistrate’s decision modifying parenting time for the parties’ minor son C.K., and partially granting a contempt finding and awards. The court held that modification was in C.K.’s best interest based on evidence that he was triggered by mother and preferred to reside primarily with father; the court found father in contempt only for failing to pay child support, not for other alleged violations. The court also affirmed allocation of guardian ad litem fees (split roughly two-thirds to father) and a small $500 attorney-fee award to mother.