Ho v. Co

2025 Ohio 1427
CourtOhio Court of Appeals
DecidedApril 23, 2025
DocketC-240338
StatusPublished

This text of 2025 Ohio 1427 (Ho v. Co) 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
Ho v. Co, 2025 Ohio 1427 (Ohio Ct. App. 2025).

Opinion

[Cite as Ho v. Co, 2025-Ohio-1427.]

IN THE COURT OF APPEALS FIRST APPELLATE DISTRICT OF OHIO HAMILTON COUNTY, OHIO

CHIA-CHI HO, : APPEAL NO. C-240338 TRIAL NO. DR-2001507 Plaintiff-Appellant, :

vs. : OPINION CARLOS CHUA CO, :

Defendant-Appellee. :

Appeal From: Hamilton County Court of Common Pleas, Domestic Relations Division

Judgment Appealed From Is: Affirmed

Date of Judgment Entry on Appeal: April 23, 2025

Chia-Chi Ho, pro se,

Carlos Chua Co, pro se. OHIO FIRST DISTRICT COURT OF APPEALS

BOCK, Judge.

{¶1} In this postdecree-divorce action, plaintiff-appellant Dr. Chia-Chi Ho

appeals the trial court’s order, which held her in civil contempt and threatened jail

time as a sanction for failing to pay $25,093.79 in interest on an outstanding

equalization payment owed to her ex-husband, defendant-appellee Dr. Carlos Chua

Co. In a single assignment of error, Dr. Ho raises procedural and substantive

challenges to the trial court’s order.

{¶2} We overrule Dr. Ho’s assignment of error. First, any deficiency in the

service of the trial court’s order did not render the order void. Second, interest on the

outstanding equalization payment properly accrued during the pendency of an appeal.

Third, Dr. Ho’s vexatious-litigator status did not prevent her from submitting

responsive filings in opposition to Dr. Co’s motions for contempt. Finally, the omission

of transcripts of the contempt hearings prevents us from reaching the merits of her

substantive challenges to the trial court’s contempt order.

{¶3} We affirm the trial court’s judgment.

I. Factual and Procedural History

{¶4} Dr. Ho and Dr. Co were divorced by decree in July 2022. See Ho v. Co,

2023-Ohio-3698, ¶ 6 (1st Dist.) (“Ho I”). Since then, this court has addressed a variety

of postdecree issues in five appeals. Months ago, we recited the “nuanced tapestry” of

the case to contextualize the issues that have come before this court:

We previously reviewed the underlying divorce decree in [Ho I], issues

pertaining to the award of GAL fees in Ho v. Co, 2024-Ohio-2424 (1st

Dist.) (“Ho II”), and a vexatious-litigator determination in Ho v. Evans,

2024-Ohio-5184 (1st Dist.) (“Ho III”).

Ho v. Co, 2024-Ohio-5895, ¶ 2 (1st Dist.) (“Ho IV”). OHIO FIRST DISTRICT COURT OF APPEALS

{¶5} Then in Ho IV, Dr. Ho challenged “an array of decisions by the trial

court concerning procedural issues, contempt, attorney’s fees, and underlying custody

issues.” Id. at ¶ 1. The contempt order at issue in Ho IV concerned Dr. Ho’s obligation

to pay the remaining $368,000 of the equalization payment owed to Dr. Co as part of

the trial court’s division of property. Id. at ¶ 3. While the trial court sentenced her to

ten days in jail for her contempt, we held that her appeal was moot after she purged

her contempt and paid Dr. Co. Id. at ¶ 26.

{¶6} Relevant here, in August 2023, Dr. Co filed a “MOTION FOR

HEARING, MOTION FOR PAYMENT, MOTION FOR INTEREST” seeking an order

instructing Dr. Ho to pay the outstanding equalization-payment balance, attorney

fees, and “interest on the outstanding amount owed to [Dr. Co].” Dr. Co noted that the

interest rate prescribed by the tax commissioner for R.C. 5703.47 was three percent in

2022 and five percent in 2023.

{¶7} At a hearing, Dr. Ho argued that she was unable to pay the equalization

payment due to exorbitant guardian ad litem (“GAL”) fees. See Ho II, 2024-Ohio-

2424, at ¶ 24 (1st Dist.) (noting that the more than $150,000 “GAL fees at issue in this

case exceed by a large margin any reported Ohio case that we could find and shock the

conscience”). The trial court granted Dr. Co’s motion for interest and ordered Dr. Ho

to pay “$368,408 before the hearing on 11/21/2023. She also owes interest at the rate

of 3%.” While the order identified the interest rate, it failed to include a dollar amount

or effective date.

{¶8} In November 2023, Dr. Ho filed an affidavit of disqualification of the

trial court judge in the Supreme Court of Ohio. Citing that affidavit of disqualification,

Dr. Ho moved to stay the equalization- and interest-payment order and argued that

her affidavit deprived the trial court of its authority over the case. Her affidavit of

3 OHIO FIRST DISTRICT COURT OF APPEALS

disqualification was ultimately denied.

{¶9} Recognizing the uncertainty surrounding the trial court’s interest

award, Dr. Co filed a “motion to clarify” and requested “the interest be ordered back

to December 20, 2021[,] for the amount remaining.” In response, Dr. Ho objected “to

the motion for interest,” arguing that the trial court’s property division did not award

Dr. Co interest and that modifying the property division constituted “an unfair

surprise.” Before the January 2024 hearing, Dr. Ho filed a successive affidavit of

disqualification of the trial court judge with the Supreme Court of Ohio. See Ho v. Co

(In re Sundermann), 2023-Ohio-4884, ¶ 1. Once again, it was denied. Id. In early

January 2024, the trial court denied Dr. Ho’s motion to stay.

{¶10} In February 2024, the trial court journalized an order stating that Dr.

Ho “owes interest on said amount at the rate of 3% effective back to December 20,

2021[,] and compounded annually.” In another order, the trial court found Dr. Ho in

contempt for nonpayment of the equalization payment and sentenced her to ten days

in jail, beginning the following month. Dr. Ho ultimately purged that contempt with a

payment to Dr. Co of the remainder of the equalization payment.

{¶11} In early April 2024, Dr. Co moved to compel Dr. Ho’s payment of

$25,093.79 in interest and pointed out that the trial court failed to set a “specific date

for payment.” Later that month, the trial court found Dr. Ho in contempt for

nonpayment of attorney fees and noted, “Although [Dr. Ho] paid the equalization

payment of $368,408 to [Dr. Co], she did not pay the 3% interest totaling $25,093.79.”

It directed Dr. Ho to “pay the interest totaling $25,093.79 on or before 5/13/24.”

{¶12} After a May 2024 hearing, the trial court found that Dr. Ho “has not paid

to [Dr. Co] the interest totaling $25,093.79 on the equalization payment, as ordered.”

It imposed “10 consecutive days of incarceration commencing 7/22/2024” and

4 OHIO FIRST DISTRICT COURT OF APPEALS

informed Dr. Ho that she could avoid that sentence and purge her contempt if she paid

Dr. Co. the interest in full.

II. Analysis

{¶13} On appeal, Dr. Ho raises several procedural and substantive issues with

the trial court’s order of contempt and the underlying interest payment.

A. Dr. Ho involuntarily purged her contempt

{¶14} As a threshold matter, Dr. Co argues that Dr. Ho paid the interest on the

equalization payment, which purged her contempt and avoided jail. He appears to

argue that her appeal is moot. Dr. Ho responds and maintains that her payment was

involuntary and not moot. We agree with Dr. Ho.

{¶15} Our review is limited to actual controversies capable of resolution by a

judgment that can be carried into effect. See Cincinnati Gas & Elec. Co. v. PUC, 2004-

Ohio-5466, ¶ 17. When issues before this court are no longer live, the appeal is moot

and beyond the scope of our review. See Hammond v. Hammond, 2020-Ohio-3443,

¶ 6 (1st Dist.).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Liming v. Damos
2012 Ohio 4783 (Ohio Supreme Court, 2012)
McRae v. McRae
2012 Ohio 2463 (Ohio Court of Appeals, 2012)
Kapadia v. Kapadia
2012 Ohio 808 (Ohio Court of Appeals, 2012)
Lubanovich v. McGlocklin
2015 Ohio 4618 (Ohio Court of Appeals, 2015)
Covert v. Covert, Unpublished Decision (6-28-2004)
2004 Ohio 3534 (Ohio Court of Appeals, 2004)
Janosek v. Janosek, Unpublished Decision (1-11-2007)
2007 Ohio 68 (Ohio Court of Appeals, 2007)
Goddard v. Children's Hospital Medical Center
751 N.E.2d 1062 (Ohio Court of Appeals, 2000)
Blazic v. Blazic, Unpublished Decision (8-26-2005)
2005 Ohio 4417 (Ohio Court of Appeals, 2005)
In Re Contempt of Morris
674 N.E.2d 761 (Ohio Court of Appeals, 1996)
Viock v. Stowe-Woodward Co.
569 N.E.2d 1070 (Ohio Court of Appeals, 1989)
Superior Waterproffing, Inc. v. Karnofel
2016 Ohio 6992 (Ohio Court of Appeals, 2016)
Darr v. Livingston
2017 Ohio 841 (Ohio Court of Appeals, 2017)
Baker-Chaney v. Chaney
2017 Ohio 5548 (Ohio Court of Appeals, 2017)
Crites v. Crites
2019 Ohio 1043 (Ohio Court of Appeals, 2019)
Hammond v. Hammond
2020 Ohio 3443 (Ohio Court of Appeals, 2020)
Cable Busters, L.L.C. v. Mosley
2020 Ohio 3442 (Ohio Court of Appeals, 2020)
Westmoreland v. Valley Homes Mutual Housing Corp.
328 N.E.2d 406 (Ohio Supreme Court, 1975)
Koegel v. Koegel
432 N.E.2d 206 (Ohio Supreme Court, 1982)
Pugh v. Pugh
472 N.E.2d 1085 (Ohio Supreme Court, 1984)

Cite This Page — Counsel Stack

Bluebook (online)
2025 Ohio 1427, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ho-v-co-ohioctapp-2025.