Bolden v. Carmona

CourtOhio Court of Appeals
DecidedJune 2, 2026
Docket24AP-723
StatusPublished

This text of Bolden v. Carmona (Bolden v. Carmona) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bolden v. Carmona, (Ohio Ct. App. 2026).

Opinion

[Cite as Bolden v. Carmona, 2026-Ohio-2052.]

IN THE COURT OF APPEALS OF OHIO

TENTH APPELLATE DISTRICT

Terry A. Bolden, :

Plaintiff-Appellee, : No. 24AP-723 v. : (C.P.C. No. 20DR-2592)

Jacqueline Carmona, : (REGULAR CALENDAR)

Defendant-Appellant. :

D E C I S I O N

Rendered on June 2, 2026

On brief: Jacqueline Carmona, pro se. Argued: Jacqueline Carmona.

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

DORRIAN, J. {¶ 1} Defendant-appellant, Jacqueline Carmona, appeals from a November 6, 2024 judgment of the Franklin County Court of Common Pleas, Division of Domestic Relations, adopting a magistrate’s decision denying Carmona’s motion for an order holding plaintiff-appellee, Terry A. Bolden, in contempt. For the following reasons, we affirm. I. Facts and Procedural History {¶ 2} This case began in August 2020, when Bolden filed a complaint for divorce. The divorce was finalized pursuant to an agreed judgment entry in August 2022. As relevant to this appeal, the agreed judgment entry ordered Bolden to pay spousal support of $1,300 on the first of each month for a period of 36 months. Carmona was permitted to retain the former marital residence free and clear of any claim from Bolden. She was granted 9 months to refinance the residence or, if unable to refinance the residence, to list it for sale. During the 9-month period, Carmona was granted exclusive use of the residence No. 24AP-723 2

and was responsible for mortgage payments, utilities, taxes, and other expenses associated with it. {¶ 3} On March 20, 2024, Carmona filed a motion for contempt, asserting Bolden had violated the agreed judgment entry by failing to pay spousal support, interfering with the residence transfer, intercepting mail, cashing joint checks without Carmona’s signature or consent, and sending spousal support late during family milestones, special events, and holidays. On October 29, 2024, a magistrate conducted a hearing on Carmona’s motion for contempt. The magistrate heard sworn testimony from both parties, and an audio recording of the proceedings was made. Following the hearing, the magistrate issued a decision concluding that Carmona had established by clear and convincing evidence that there were multiple instances when Bolden failed to make his monthly spousal support payment by the first day of the month. However, the magistrate further found that Bolden had a defense based on instances when he made the mortgage payment on the former marital residence because Carmona failed to timely make the payment. The magistrate found that Bolden made pro-rated spousal support payments taking into account the amounts he had paid toward the mortgage, and concluded Bolden had ultimately overpaid by approximately $1,400. The magistrate concluded Bolden’s defense was well-taken and declined to hold him in contempt for failure to make timely spousal support payments. The magistrate also found that Carmona failed to prove her allegations that Bolden interfered with the transfer of the former marital residence by clear and convincing evidence. The magistrate found that Bolden endorsed and deposited one escrow overage refund check in July 2023, but concluded that action did not violate any specific court order. Based on these findings, the magistrate denied Carmona’s motion for contempt. Carmona did not file written objections to the magistrate’s decision. On November 6, 2024, the trial court issued a judgment entry adopting the magistrate’s decision. II. Assignments of Error {¶ 4} Carmona appeals and assigns the following seven assignments of error for our review: [I.] The trial court abused its discretion by failing to comply with Sup.R. 16(E) where clear evidence of financial coercion and economic control was presented. No. 24AP-723 3

[II.] The court erred by approving a property division that exposed Appellant to foreclosure, contrary to R.C. 3105.171.

[III.] The court erred by accepting Appellant’s admission of contempt, made under financial duress and without a voluntary, knowing waiver.

[IV.] The court erred by failing to recognize Appellee’s cashing of the equity check as a fraudulent disposition of assets under R.C. 3105.171(E)(4).

[V.] The court erred in reducing the duration and amount of spousal support without considering statutory factors under R.C. 3105.18.

[VI.] The court erred by failing to award attorney’s fees and costs due to Appellee’s repeated noncompliance.

[VII.] The court erred by failing to compensate Appellant for consequential damages caused by Appellee’s misconduct.

III. Discussion {¶ 5} Two procedural issues prevent us from considering the merits of Carmona’s appeal. Although Carmona is representing herself in this matter, pro se litigants are held to the same standards that apply to litigants represented by counsel. Franklin Cty. Children Servs. v. Copley, 2022-Ohio-3406, ¶ 8 (10th Dist.), citing Zukowski v. Brunner, 2010-Ohio-1652, ¶ 8. {¶ 6} First, Carmona did not timely file objections to the magistrate’s decision in the trial court. A party may file written objections within 14 days of the filing of a magistrate’s decision. Civ.R. 53(D)(3)(b)(i). The magistrate issued his decision following the October 29, 2024 hearing. The trial court adopted the magistrate’s decision fewer than 14 days later, on November 6, 2024, which is permitted under the Civil Rules. Civ.R. 53(D)(4)(e)(i) (“The court may enter a judgment either during the fourteen days permitted by Civ.R. 53(D)(3)(b)(i) for the filing of objections to a magistrate’s decision or after the fourteen days have expired.”). Under such circumstances, a party may still file written objections within the 14-day period following the filing of the magistrate’s decision. Civ.R. 53(D)(3)(b)(i) (“A party may file written objections to a magistrate’s decision within fourteen days of the filing of the decision, whether or not the court has adopted the decision No. 24AP-723 4

during that fourteen-day period as permitted by Civ.R. 53(D)(4)(e)(i).” (Emphasis added.)). When a court has entered judgment during the 14-day period and objections are timely filed, the objections operate as an automatic stay of execution of the judgment until the court disposes of the objections. Civ.R. 53(D)(4)(e)(i). “Therefore, regardless of the trial court’s ruling on the magistrate’s decision, a party must still file objections within 14 days of the filing of the magistrate’s decision.” Hood v. Hood, 2026-Ohio-1666, ¶ 7 (10th Dist.). {¶ 7} A party that fails to file objections to a magistrate’s decision waives all but plain error on appeal. Id. at ¶ 8. See Civ.R. 53(D)(3)(b)(iv) (“Except for a claim of plain error, a party shall not assign as error on appeal the court’s adoption of any factual finding or legal conclusion, whether or not specifically designated as a finding of fact or conclusion of law under Civ.R. 53(D)(3)(a)(ii), unless the party has objected to that finding or conclusion as required by Civ.R. 53(D)(3)(b).”). “The doctrine of plain error is limited to exceptionally rare cases in which the error, left unobjected to at the trial court, rises to the level of challenging the legitimacy of the underlying judicial process itself.” McLellan v. McLellan, 2011-Ohio-2418, ¶ 7 (10th Dist.). See Goldfuss v. Davidson, 1997-Ohio-401, syllabus (“In appeals of civil cases, the plain error doctrine is not favored and may be applied only in the extremely rare case involving exceptional circumstances where error, to which no objection was made at the trial court, seriously affects the basic fairness, integrity, or public reputation of the judicial process, thereby challenging the legitimacy of the underlying judicial process itself.”).

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Related

Zukowski v. Brunner
2010 Ohio 1652 (Ohio Supreme Court, 2010)
Franklin Cty. Children Servs. v. Copley
2022 Ohio 3406 (Ohio Court of Appeals, 2022)
Goldfuss v. Davidson
1997 Ohio 401 (Ohio Supreme Court, 1997)
Hood v. Hood
Ohio Court of Appeals, 2026

Cite This Page — Counsel Stack

Bluebook (online)
Bolden v. Carmona, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bolden-v-carmona-ohioctapp-2026.