In re M.H.

2024 Ohio 1675
Ohio Court of Appeals·Decided May 1, 2024·No. 30892, 30893·Published·Cited by 1 cases

Opinion

[Cite as In re M.H., 2024-Ohio-1675.]

STATE OF OHIO ) IN THE COURT OF APPEALS )ss: NINTH JUDICIAL DISTRICT COUNTY OF SUMMIT )

IN RE: M.H. C.A. Nos. 30892 J.H. 30893

APPEAL FROM JUDGMENT ENTERED IN THE COURT OF COMMON PLEAS COUNTY OF SUMMIT, OHIO CASE Nos. DN 23 02 0143 DN 23 02 0144

DECISION AND JOURNAL ENTRY

Dated: May 1, 2024

SUTTON, Presiding Judge.

{¶1} Appellant, W.H. (“Father”), appeals from a judgment of the Summit County Court

of Common Pleas, Juvenile Division, that adjudicated his two minor children dependent and placed

one of them in the temporary custody of Summit County Children Services Board (“CSB”) and

the other in the custody of their legal custodian (“Custodian”) under the protective supervision of

CSB. This Court affirms.

I.

{¶2} Father is the biological father of J.H., born May 14, 2009; and M.H., born

December 12, 2011. Neither the children’s mother nor Custodian appealed the trial court’s

judgment.

{¶3} When this case began, both children were living with Custodian, who is a paternal

relative. The juvenile court had separately placed the children in the legal custody of Custodian 2

in 2011 and 2015 because the parents had problems with substance abuse and instability in their

lives and had been unable to resolve those problems during two prior juvenile cases. Few details

about those prior cases are included in the record.

{¶4} On February 23, 2023, CSB filed complaints to commence this case, alleging that

J.H. and M.H. were abused children because Custodian had physically harmed them by repeatedly

disciplining them with excessive corporal punishment. The complaint also alleged that the

children were dependent because there had been a “breakdown in the relationship between

Custodian and the children.” Specifically, the agency alleged that the children frequently violated

Custodian’s rules, Custodian had become unable to control their behavior, their behavioral

problems were worsening, and Custodian’s attempts to discipline the children or otherwise redirect

their misbehavior had caused them to run away from the home. The complaint further alleged that

the children’s parents still struggled with substance abuse problems and were not prepared to

provide them with a suitable home.

{¶5} The case proceeded to a contested adjudicatory hearing before a magistrate. All

parties were represented by counsel, but Mother and Custodian did not appear for the hearing.

After the hearing, the magistrate found that CSB had failed to prove that Custodian’s use of

corporal punishment rose to the level of abuse, so he dismissed the allegations of abuse. The

magistrate further found that the agency did prove that the children were dependent under R.C.

2151.04(C) because of the conditions of Custodian’s home. The magistrate focused particularly

on evidence that the parents had been seeing the children without Custodian’s permission and

interfering with Custodian’s ability to care for the children; both children had been demonstrating

an increase in behavioral problems at school and at home, including lying, stealing, running away, 3

and other disruptive behaviors; and Custodian at times became overwhelmed with caring for the

children.

{¶6} The only party who filed objections to the magistrate’s decision was Father, who

raised several separate arguments, including that the court improperly considered certain evidence

and that the dependency decision was not supported by the evidence presented at the hearing. The

trial court explicitly addressed some of Father’s arguments and summarily overruled the remainder

of his objections. The trial court adjudicated the children dependent under R.C. 2151.04(C) and

placed J.H. in the temporary custody of CSB and placed M.H. with Custodian under an order of

protective supervision by CSB. Father appeals and raises five assignments of error, all of which

pertain to the trial court’s adjudication of the children.

II.

ASSIGNMENT OF ERROR I

THE TRIAL COURT COMMITTED REVERSIBLE ERROR BY NOT EXPLICITLY MAKING A SPECIFIC RULING ON EACH ONE OF FATHER’S OBJECTIONS, AND THEREFORE THE TRIAL COURT FAILED TO ISSUE A FINAL, APPEALABLE ORDER.

{¶7} Father’s first assignment of error challenges the trial court’s failure to issue an

explicit ruling on each of his objections to the magistrate’s decision. His assigned error, as stated,

asserts that the court’s failure to articulate a ruling on each objection constituted reversible error

and also affected the finality of the trial court’s judgment. Ultimately, Father “requests that this

Court dismiss this appeal for lack of a final, appealable order[.]”

{¶8} In support of his argument that the trial court did not issue a final, appealable order,

Father relies on case law from other appellate districts. See, e.g., Sullivan v. Pittman, 5th Dist.

Licking No. 2021 CA 00069, 2022-Ohio-1211, ¶ 22. This Court is not persuaded by that line of

reasoning. 4

{¶9} In Miller v. Miller, 9th Dist. Medina No. 10CA0034-M, 2011-Ohio-4299, this

Court overruled prior decisions holding that the trial court’s failure to explicitly rule on objections

under Civ.R. 53(D) or Juv.R. 40(D) affected the appealability of its judgment, based on an

amendment to App.R. 4(B)(2) that became effective on July 1, 2011. Since then, this Court has

consistently held that a trial court’s failure to explicitly rule on every objection to a magistrate’s

decision does not affect the finality of the trial court’s judgment. See, e.g., Mistysyn v. Lynch, 9th

Dist. Lorain No. 18CA011317, 2019-Ohio-903, ¶ 7; In re R.R., 9th Dist. Summit No. 27572, 2015-

Ohio-5245, ¶ 15.

{¶10} Moreover, insofar as Father alleges error in the trial court’s failure to explicitly

overrule each of his objections, as will be explained in more detail below, the trial court explicitly

or implicitly overruled each of Father’s objections to the magistrate’s adjudicatory decision. The

trial court recognized that some of Father’s objections alleged actual error in the admission of

certain evidence. It summarily overruled his evidentiary objections, however, because the

evidence pertained solely to CSB’s allegations that Custodian’s use of corporal punishment rose

to the level of abuse. The trial court explained that, because the allegations of abuse had been

dismissed, any error in the admission of evidence pertaining to alleged abuse was harmless.

{¶11} Consequently, Father has failed to demonstrate a lack of finality in the trial court’s

judgment or that the trial court erred by failing to issue explicit rulings on each of his objections

to the magistrate’s adjudicatory decision. Father’s first assignment of error is overruled.

ASSIGNMENT OF ERROR II

THE TRIAL COURT COMMITTED REVERSIBLE ERROR IN OVERRULING FATHER’S OBJECTIONS TO THE MAGISTRATE’S ADJUDICATORY DECISION BY CONSIDERING INADMISSIBLE EVIDENCE THAT VIOLATED THE RULES OF EVIDENCE. 5

ASSIGNMENT OF ERROR III

THE TRIAL COURT COMMITTED REVERSIBLE ERROR IN OVERRULING FATHER’S OBJECTIONS TO THE MAGISTRATE’S ADJUDICATORY DECISION BY ALLOWING [CSB] TO IMPROPERLY REFRESH A WITNESS’S MEMORY IN VIOLATION OF EVID.R. 803(5) AND EVID.R. 612.

ASSIGNMENT OF ERROR IV

THE TRIAL COURT COMMITTED REVERSIBLE ERROR IN OVERRULING FATHER’S OBJECTIONS TO THE MAGISTRATE’S ADJUDICATORY DECISION BY CONSIDERING EVIDENCE [OF EVENTS THAT OCCURRED] AFTER THE FILING OF CSB’S COMPLAINT.

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

In re M.H., 2024 Ohio 1675 (Ohio Ct. App. 2024).

2024 Ohio 1675 (In re M.H.) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

In re A.M.
2025 Ohio 4435 (Ohio Court of Appeals, 2025)