In re B.M.

2026 Ohio 264
CourtOhio Court of Appeals
DecidedJanuary 29, 2026
Docket115239
StatusPublished

This text of 2026 Ohio 264 (In re B.M.) 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
In re B.M., 2026 Ohio 264 (Ohio Ct. App. 2026).

Opinion

[Cite as In re B.M., 2026-Ohio-264.]

COURT OF APPEALS OF OHIO

EIGHTH APPELLATE DISTRICT COUNTY OF CUYAHOGA

IN RE B.M. : No. 115239 A Minor Child :

[Appeal by J.M., Father] :

JOURNAL ENTRY AND OPINION

JUDGMENT: REVERSED AND REMANDED RELEASED AND JOURNALIZED: January 29, 2026

Civil Appeal from the Cuyahoga County Court of Common Pleas Juvenile Division Case No. CU16102653

Appearances:

Jeffrey V. Hawkins, for appellant.

Michael C. O’Malley, Cuyahoga County Prosecuting Attorney, and Marilyn Orkin Weinberg, Assistant Prosecuting Attorney, for appellee Office of Child Support Services.

EILEEN T. GALLAGHER, J.:

Appellant J.M. challenges the judgment of the juvenile court denying

his motion to compel A.M. (“Mother”) to cooperate with genetic testing and his

motion to release him from paternity of the minor child, B.M. (d.o.b. 10/7/2008).

He raises one assignment of error: The trial court erred and abused its discretion by failing to facilitate the genetic testing of the minor child and the mother by therefore overruling the Father’s Application for Release from Paternity findings.

After a thorough review of the applicable law and facts, we find that the

trial court erred in determining that it lacked jurisdiction to consider J.M.’s motion

for release from paternity and denying his motion to compel as moot. We sustain

J.M.’s sole assignment of error, reverse the judgment of the trial court, and remand

for the court to (1) determine whether Mother willfully failed to submit B.M. for

genetic testing, and (2) properly consider J.M.’s motion for release from paternity.

I. Factual and Procedural History

Paternity of B.M. had been established in 2008 via voluntary

acknowledgement after J.M. signed an affidavit stating that he was the natural

father of B.M. and assumed the parental duty of her support. There is no dispute

that the affidavit was never rescinded nor had any action been commenced under

R.C. 3111.28 to rescind the acknowledgment.

In February 2016, J.M. filed an application to determine custody,

parenting time, shared parenting plan, companionship, and visitation of B.M.1 As

part of the application, J.M. asserted that paternity had been established. He sought

custody, parenting time, shared parenting, or visitation, asserting that the current

living arrangements were not healthy or in B.M.’s best interest.

1 The underlying action also pertained to two other minor children, who are now

emancipated. Because this appeal only concerns B.M., we will address the facts and issues solely as they relate to her. The magistrate designated both J.M. and Mother as residential parents

and legal custodians. Mother was granted parenting time on the weekends, and

B.M. was to be with J.M. the remainder of the time.

Mother objected to the magistrate’s decision, arguing that J.M. was not

the biological father of B.M. and moved to stay the proceedings. She attached to her

objections the results of recent genetic testing showing that another individual was

B.M.’s biological father. Mother noted that the results of the genetic testing had not

been available at the time of the custody hearing.

The juvenile court overruled Mother’s objections and adopted the

decision of the magistrate.

Mother subsequently filed a motion for relief from paternity

determination, motion to disestablish paternity, request for genetic testing, and a

motion to stay the decision granting custody to J.M. J.M. opposed these motions,

arguing that they were barred by res judicata because Mother had already raised the

potential argument that J.M. might not be the father of B.M. The court denied all of

Mother’s motions because paternity had already been established at the time of

B.M.’s birth.

In August 2019, J.M. moved to modify the custody order, seeking full

custody of B.M. He asserted that Mother had not seen or tried to contact her in

several weeks and had been inconsistent with her parenting time.

The court granted the motion to modify in January 2021 but

designated Mother as the residential parent and legal custodian of B.M. and terminated the parties’ shared parenting plan. The court noted that J.M. had not

executed a proposed agreed judgment entry regarding custody and had failed to

appear at the motion hearing.

Mother subsequently sought child support from J.M., and the Office of

Child Support Services was permitted to intervene as a party in July 2024.

In January 2025, J.M. filed a motion for release from paternity

determination pursuant to R.C. 3119.961, arguing that a genetic test had established

that he was not the biological father of B.M. He stated that these test results were

attached as an exhibit to his motion; however, the genetic-test results attached to

the motion were the same genetic-test results from March 2017 pertaining to the

probability that another individual was the father of B.M. and did not make any

determination as to J.M.’s probability of paternity.2

The magistrate determined that J.M.’s motion had not complied with

the requirements of R.C. 3119.96, et seq. The court granted J.M. leave until

March 14, 2025, to present genetic-test results not older than six months that

demonstrated a zero percent probability that J.M. was the father of B.M. and to file

the appropriate pleading under the statutes. The court warned that failure to comply

could result in the denial of the motion without further hearing.

On March 18, 2025, J.M. filed a motion to compel Mother to cooperate

with genetic testing and to extend the deadline to file genetic-test results. In support

2 The testing concluded that the probability that the other individual was the father of B.M.

was 99.99999999%. of his motion, J.M. submitted a copy of an email from January 24, 2025, that he had

sent to his attorney stating that he had completed his part of the genetic testing. He

also attached two emails sent by his attorney to Mother regarding genetic testing.

The first was dated January 27, 2025, and asked her to arrange for genetic testing;

the second email was from February 10, 2025, inquiring if Mother had completed

the testing. J.M. did not present any evidence of any responsive communications by

Mother regarding the genetic testing.

In reviewing J.M.’s motion, the magistrate determined:

The Court finds that the statute clearly requires that the father first obtain the genetic test results that are no older than six (6) months to attach to his motion for relief. The jurisdiction to address the motion is not invoked until the proper filing is made and service is perfected upon all necessary parties. This has not occurred in this case.

The magistrate denied the motion to release for failure to state a claim

upon which relief could be granted and denied the motion to compel and motion to

extend as moot.

J.M. filed objections to the magistrate’s decision, arguing that all

parties, along with the court, knew that he was not the father of B.M. He asserted

that the court was required to order Mother to submit the child to genetic testing

under R.C. 3119.963.

The trial court overruled the objections and adopted the decision of

the magistrate. J.M. then filed the instant appeal. II. Law and Analysis

Under R.C. 3119.961(A), a person may file a motion for relief from a

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

Related

Hardy v. Wilson, Unpublished Decision (9-5-2006)
2006 Ohio 4532 (Ohio Court of Appeals, 2006)
State Ex Rel. Rojas v. Guilfu, Unpublished Decision (12-9-2004)
2004 Ohio 6707 (Ohio Court of Appeals, 2004)
Dragon v. Dragon
2016 Ohio 7304 (Ohio Court of Appeals, 2016)

Cite This Page — Counsel Stack

Bluebook (online)
2026 Ohio 264, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-bm-ohioctapp-2026.