Jackson v. Tyler

[Cite as Jackson v. Tyler, 2026-Ohio-1435.]


                              IN THE COURT OF APPEALS OF OHIO

                                   TENTH APPELLATE DISTRICT


Jessica L. Jackson,                                 :

                 Plaintiff-Appellant,               :              No. 25AP-662
                                                                (C.P.C. No. 24JU-6866)
v.                                                  :
                                                         (ACCELERATED CALENDAR)
Rajael H. Tyler,                                    :

                 Defendant-Appellee.                :




                                              D E C I S I O N

                                      Rendered on April 21, 2026


                 On brief: Jessica L. Jackson, pro se. Argued: Jessica L.
                 Jackson.

                  APPEAL from the Franklin County Court of Common Pleas,
                      Division of Domestic Relations, Juvenile Branch

LELAND, J.
        {¶ 1} Plaintiff-appellant, Jessica L. Jackson, challenges the judgment of the
Franklin County Court of Common Pleas, Division of Domestic Relations, Juvenile Branch,
adopting a July 16, 2025 magistrate’s decision that ordered defendant-appellee, Rajael H.
Tyler, to pay child support.
I. Facts and Procedural History
        {¶ 2} On July 1, 2024, appellant filed a complaint against appellee in the trial court
seeking child support and designation as the sole residential parent and legal custodian of
the parties’ minor child, J.J. The complaint indicated paternity had not yet been
established. On October 29, 2024, appellant filed an amended complaint seeking to
establish paternity, in addition to the requests of the original complaint. On March 12,
2025, the court ordered genetic testing for appellee and J.J. On May 6, 2025, the court’s
No. 25AP-662                                                                                  2


magistrate held a hearing on J.J.’s parentage and living arrangement. On July 8, 2025, the
magistrate held a hearing on the issue of child support. The magistrate filed two separate
decisions on July 16, 2025. The decision related to the May 6, 2025 hearing established
appellee’s parentage of J.J., granted appellant’s request to be named J.J.’s sole residential
parent and legal custodian, and granted appellee parenting time. The decision, related to
the July 8, 2025 hearing, ordered appellee to pay child support in the amount of about $140
per month. Neither party filed objections to the magistrate’s decisions. In two separate
orders filed August 6, 2025, the court adopted the magistrate’s decisions as its own and
entered final judgment.
       {¶ 3} Appellant timely appealed.
II. Assignments of Error
       {¶ 4} Appellant assigns the following as errors for our review:
              [I.] The court erred in predicating a ruling that excluded
              evidence after Plaintiff’s offer of proof, which was not found
              inadmissible by the court.

              [II.] The Plaintiff [sic] and his counsel knowingly lied under
              oath.

III. Discussion
       {¶ 5} Both of appellant’s assignments allege error on the basis of testimony at the
July 8, 2025 hearing before the magistrate. We consider these assignments of error
together.
       {¶ 6} Appellant did not file objections to the magistrate’s decision relating to the
July 8, 2025 hearing. As a result, the trial court record did not contain the transcript of that
hearing when the court adopted the magistrate’s decision. “An appellate court may review
the record only as it existed at the time the trial court rendered its judgment.” (Internal
quotation marks omitted.) In re G.B., 2024-Ohio-5927, ¶ 9 (10th Dist.); see Tucker v.
Hines, 2020-Ohio-1086, ¶ 8 (10th Dist.); Townsend v. Phommarath, 2011-Ohio-1891, ¶ 7-
9 (10th Dist.). Just as the court did not have the transcript of the July 8, 2025 magistrate’s
hearing when it adopted the magistrate’s decision, we will not consider the transcript in our
review. G.B. “In cases where the transcript is necessary to decide the assignment of error
before us, we are obligated to presume the validity of the trial court’s proceedings and affirm
its decision.” Id.
No. 25AP-662                                                                               3


       {¶ 7} Additionally, appellant’s failure to object to the magistrate’s decision results
in a waiver of “all but plain error in the trial court’s decision.” Townsend at ¶ 8;
Juv.R. 40(D)(3)(b)(iv). “The plain error doctrine originated as a criminal law concept,” so
we apply it in the civil context only “with the utmost caution,” and only to “those extremely
rare cases where exceptional circumstances require its application to prevent a manifest
miscarriage of justice, and where the error complained of, if left uncorrected, would have a
material adverse effect on the character of, and public confidence in, judicial proceedings.”
Goldfuss v. Davidson, 1997-Ohio-401, ¶ 24; see In re Estate of Fogle, 2026-Ohio-911, ¶ 23
(10th Dist.).
       {¶ 8} Neither of appellant’s assignments of error assert plain error, and, because
she waived all but plain error by failing to object to the magistrate’s decision, we must
overrule them both. Even if appellant did allege plain error on appeal, the record does not
contain a transcript of the magistrate’s hearing. This thwarts our review of the purported
errors in the magistrate’s hearing and requires that we presume the validity of the trial
court’s proceedings. G.B. at ¶ 9. Accordingly, we overrule the first and second assignments
of error.
IV. Conclusion
       {¶ 9} Based on the foregoing, we overrule both of appellant’s assignments of error
and affirm the judgment of the Franklin County Court of Common Pleas, Division of
Domestic Relations, Juvenile Branch.
                                                                       Judgment affirmed.

                          DORRIAN and JAMISON, JJ., concur.