In re K.M.

2024 Ohio 1395
CourtOhio Court of Appeals
DecidedApril 12, 2024
Docket24CA000002
StatusPublished

This text of 2024 Ohio 1395 (In re K.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 K.M., 2024 Ohio 1395 (Ohio Ct. App. 2024).

Opinion

[Cite as In re K.M., 2024-Ohio-1395.]

COURT OF APPEALS GUERNSEY COUNTY, OHIO FIFTH APPELLATE DISTRICT

IN RE: K.M. JUDGES: Hon. Patricia A. Delaney, P.J. Hon. William B. Hoffman, J. Hon. Andrew J. King, J.

Case No. 24CA000002

OPINION

CHARACTER OF PROCEEDINGS: Appeal from the Guernsey County Court of Common Pleas, Juvenile Division, Case No. 23JG00337

JUDGMENT: Reversed and Remanded

DATE OF JUDGMENT ENTRY: April 12, 2024

APPEARANCES:

For Plaintiff-Appellee For Defendant-Appellant

SCOTT T. HILLIS Law Office of Scott T. Hillis, L.L.C. 3670 Harmony Lane Zanesville, Ohio 43701 Guernsey County, Case No. 24CA000002 2

Hoffman, J. {¶1} Defendant-appellant Heather North (hereinafter “Mother”) appeals the

judgment entered by the Guernsey County Common Pleas Court, Juvenile Division,

awarding legal custody of her daughter, K.M., to Plaintiff-appellee, Amy Stewart, the

child’s paternal grandmother (hereinafter “Grandmother”).1

STATEMENT OF THE CASE2

{¶2} Grandmother filed a motion in the Guernsey County Common Pleas Court,

Juvenile Division, seeking legal custody of K.M. Although Guernsey County Children’s

Services was involved with the family, they are not a party to the custody case, and had

not filed a complaint alleging the child was dependent, neglected, or abused. The case

proceeded to a hearing before a magistrate on December 20, 2023, at which both parties

appeared pro se.

{¶3} The magistrate found the testimony presented at the hearing established

Mother was moving in the right direction in addressing the concerns of Children’s

Services. However, concerns remained about domestic violence between Mother and

Father. The magistrate found both parents resided at the same hotel, and Mother did not

provide a safe living environment for K.M. The magistrate found “the best interests of

[K.M.] are served by placing her in the legal custody of Amy Stewart.” Decision of

Magistrate, December 21, 2023. The trial court adopted the report of the magistrate as

the decision of the court by judgment entry timestamped the same date and time as the

decision of the magistrate.

1 Grandmother has not filed a brief in the instant appeal. 2 A rendition of the facts is not necessary for resolution of the issues raised on appeal. Guernsey County, Case No. 24CA000002 3

{¶4} It is from the December 21, 2023, judgment of the trial court Mother

prosecutes her appeal, assigning as error:

I. THE TRIAL COURT COMMITTED REVERSIBLE ERROR BY

AWARDING LEGAL CUSTODY OF K.M. TO A NON-PARENT WITHOUT

FINDING BY A PREPONDERANCE OF THE EVIDENCE THAT THE

PARENTS WERE UNSUITABLE.

II. THE TRIAL COURT COMMITTED REVERSIBLE ERROR BY

GRANTING CUSTODY OF K.M. TO THE APPELLEE WITHOUT FIRST

APPOINTING A GUARDIAN AD LITEM FOR THE MINOR CHILD.

{¶5} This case comes to us on the accelerated calendar. App.R. 11.1, which

governs accelerated calendar cases, provides, in pertinent part:

(E) Determination and judgment on appeal.

The appeal will be determined as provided by App.R. 11.1. It shall

be sufficient compliance with App.R. 12(A) for the statement of the reason

for the court's decision as to each error to be in brief and conclusionary

form.

The decision may be by judgment entry in which case it will not be

published in any form. Guernsey County, Case No. 24CA000002 4

{¶6} This appeal shall be considered in accordance with the aforementioned

rule.

I.

{¶7} In her first assignment of error, Mother argues the trial court erred by

applying the wrong legal standard to a custody determination between a parent and a

nonparent.

{¶8} At the outset, we note Mother failed to file objections to the magistrate’s

decision. We also note the trial court filed its decision stamped “final appealable order”

on the same date and at the same time the magistrate’s decision was filed, the day after

the hearing. Juv. R. 4(D)(3)(b)(iv) provides:

(iv) Waiver of Right to Assign Adoption by Court as Error on Appeal.

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

Juv.R. 40(D)(3)(a)(ii), unless the party has objected to that finding or

conclusion as required by Juv.R. 40(D)(3)(b).

{¶9} Based on this Rule, in the absence of an objection, we review this issue for

plain error.

{¶10} The Ohio Supreme Court has set forth the standard applicable to a custody

proceeding between a parent and nonparent: Guernsey County, Case No. 24CA000002 5

Ohio courts have sought to effectuate the fundamental rights of

parents by severely limiting the circumstances under which the state may

deny parents the custody of their children. In re Perales (1977), 52 Ohio

St.2d 89, 6 O.O.3d 293, 369 N.E.2d 1047, syllabus. Accordingly, we have

held that in a child custody proceeding between a parent and nonparent, a

court may not award custody to the nonparent “without first determining that

a preponderance of the evidence shows that the parent abandoned the

child; contractually relinquished custody of the child; that the parent has

become totally incapable of supporting or caring for the child; or that an

award of custody to the parent would be detrimental to the child.” Id. If a

court concludes that any one of these circumstances describes the conduct

of a parent, the parent may be adjudged unsuitable, and the state may

infringe upon the fundamental parental liberty interest of child custody.

Thus, a finding of parental unsuitability has been recognized by this

court as a necessary first step in child custody proceedings between a

natural parent and nonparent.

{¶11} In re Hockstok, 98 Ohio St.3d 238, 2002-Ohio-7208, 781 N.E.2d 971, ¶¶

17-18.

{¶12} The trial court applied a “best interests” standard to the custody

determination, finding the award of legal custody to Grandmother to be in K.M.’s best

interests. The trial court failed to make a finding Mother was unsuitable, which was a

necessary first step in the instant custody proceeding between Mother and Grandmother. Guernsey County, Case No. 24CA000002 6

We find the failure to make the required finding of unsuitability is plain error in the instant

case.

{¶13} The first assignment of error is sustained.

II.

{¶14} In her second assignment of error, Mother argues the trial court erred in

failing to appoint guardian ad litem for K.M.

{¶15} Juv. R. 4(B)(2) provides:

(B) Guardian ad Litem; When Appointed. The court shall appoint a

guardian ad litem to protect the interests of a child or incompetent adult in

a juvenile court proceeding when:

(2) The interests of the child and the interests of the parent may

conflict[.]

{¶16} The plain language of Juv.R. 4(B) mandates appointment of a guardian ad

litem when the interests of the child and the parent “may” conflict. Nevertheless, “the

juvenile court is in the best position to weigh the relevant facts in determining whether a

potential conflict of interest exists between the parent and child.” In re Sappington, 123

Ohio App.3d 448, 453–454, 704 N.E.2d 339

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Related

Hockstok v. Hockstok
2002 Ohio 7208 (Ohio Supreme Court, 2002)
In Re Sappington
704 N.E.2d 339 (Ohio Court of Appeals, 1997)
Perales v. Nino
369 N.E.2d 1047 (Ohio Supreme Court, 1977)

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Bluebook (online)
2024 Ohio 1395, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-km-ohioctapp-2024.