In re S.N.A.-K.

2024 Ohio 4494
CourtOhio Court of Appeals
DecidedSeptember 12, 2024
Docket113677
StatusPublished

This text of 2024 Ohio 4494 (In re S.N.A.-K.) 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 S.N.A.-K., 2024 Ohio 4494 (Ohio Ct. App. 2024).

Opinion

[Cite as In re S.N.A.-K., 2024-Ohio-4494.]

COURT OF APPEALS OF OHIO

EIGHTH APPELLATE DISTRICT COUNTY OF CUYAHOGA

IN RE S.N.A-K. : : No. 113677 A Minor Child : : [Appeal by S.M.F., Mother] :

JOURNAL ENTRY AND OPINION

JUDGMENT: AFFIRMED RELEASED AND JOURNALIZED: September 12, 2024

Civil Appeal from the Cuyahoga County Court of Common Pleas Juvenile Division Case No. FA21705753

Appearances:

S.M.F., pro se.

EMANUELLA D. GROVES, J.:

Appellant-mother, S.M.F. (“Mother”), pro se, appeals from the

decision of the Juvenile Division of the Cuyahoga County Court of Common Pleas

(the “Juvenile Court”) that denied her motion to modify custody. For the reasons

that follow, we affirm the Juvenile Court’s decision. Facts and Procedural History

In December 2022, Father was granted legal custody of the child,

S.N.A-K. Between June and October 2023, Mother, acting pro se, filed four motions

before the juvenile court: a motion to show cause, a motion to modify custody, a

motion to waive GAL fees, and a motion for appointment of a medical expert. The

guardian ad litem (“GAL”) recommended no changes to the current schedule or

custody except for the holidays. On January 22, 2024, a magistrate heard testimony

on Mother’s motions. The magistrate heard testimony from Mother, Father, and the

GAL. Ultimately, the magistrate denied Mother’s motions and filed the decision on

January 22, 2024. Mother did not file a transcript or an objection to the decision of

the magistrate. On February 7, 2024, the juvenile court approved the magistrate’s

decision. The juvenile court found that Mother failed to meet the burden of proof

on her motion to show cause where she had alleged that Father refused to allow

her access to medical and educational records. The juvenile court also denied

Mother’s motion to modify custody based on Father’s alleged medical neglect of

the child. The juvenile court also denied Mother’s motion to waive GAL fees and

her request to appoint a medical expert to determine whether S.N.A-K. was

medically neglected. The court found the issue moot as the GAL had spoken to the

child’s pediatricians who did not find the child medically neglected.

Subsequently, Mother filed an appeal and raises one assignment of

error for our review. Assignment of Error

The trial court erred and abused its discretion and power in determining the physical custody of S.N.A-K. (Ohio revised code, Title 31 Ch.3109, Section 3109.042, and 3109.043) The Guardian Ad Litem’s testimony should be stricken from the record. The Guardian Ad Litem’s investigation fell far short of the minimum standards established by the Ohio Supreme Court.

Law and Analysis

As a preliminary matter, we note that pro se litigants are held to the

same standards as litigants who are represented by attorneys. In re C.T.T., 2019-

Ohio-3362, ¶ 9 (8th Dist.). Additionally, they are presumed to have knowledge of

legal procedures and the law. Id.

In the instant case, Mother failed to file a transcript of proceedings

with the juvenile court nor did she file objections to the decision of the magistrate.

Magistrate’s decisions and the procedure for filing and ruling on objections to a

magistrate’s decision are governed by Juv.R. 40. In re A.C., 2019-Ohio-5127, ¶ 18

(8th Dist.). A party has 14 days after the magistrate’s decision is filed to file

objections. Juv.R. 40(D)(3)(b)(i). If a party timely objects, the juvenile court is

required to “undertake an independent review as to the objected matters to

ascertain that the magistrate has properly determined the factual issues and

appropriately applied the law.” Juv.R. 40(D)(4)(d). This “independent review” is

a de novo review of the facts and requires the juvenile court to reach its own

conclusions about the case issues. In re A.C. at ¶ 18, citing Radford v. Radford,

2011-Ohio-6263, ¶ 13 (8th Dist.). To this end, the party objecting must file “a transcript of all the evidence submitted to the magistrate relevant to that finding

or an affidavit of that evidence if a transcript is not available.” Juv.R.

40(D)(3)(b)(iii).

If a party fails to object to the decision of the magistrate and follow

the procedures established in Juv.R. 40, with the exception of plain error, the

“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).” Juv.R. 40(D)(3)(b)(iv).

As Mother failed to object, the juvenile court was only “required to

review the [magistrate’s] decision to determine whether an error of law or other

defect existed on the face of the magistrate’s decision.” In re S.H., 2014-Ohio-

4476, ¶ 11 (8th Dist.). Additionally, where a party fails to file a transcript of the

proceedings, the juvenile court “may properly adopt a magistrate’s factual findings

without further consideration.” Id. at ¶ 13.

As a result, as a reviewing court, this court is limited to considering

whether plain error occurred. Id. at ¶ 12. In civil cases, courts are advised to

proceed with the “utmost caution” and limit application of plain error “to those

extremely rare cases where exceptional circumstances require its application to

prevent a manifest miscarriage of justice.” Goldfuss v. Davidson, 79 Ohio St.3d

116, 121 (1997). Furthermore, because Mother failed to file a transcript with the

juvenile court, we are precluded from considering the transcript of the magistrate’s hearing that Mother submitted as part of the record on appeal. In re S.H. at ¶ 14,

citing In re A.L., 2013-Ohio-5120, ¶ 12.

The juvenile court is given broad discretion in custody issues. In re

A.B., 2021-Ohio-4613, ¶ 28 (8th Dist.). These decisions will not be disturbed unless

the juvenile court abused its discretion. Id. An abuse of discretion implies the

court’s attitude is unreasonable, arbitrary, or unconscionable. Id.

Mother challenges the GAL’s investigation, arguing that he failed to

comply with the rules under which he is governed. Mother cites to the Ohio

Supreme Court Rules of Superintendence in support of her argument that the GAL

violated several sections of Rule 48.03 which discusses the responsibilities of a

guardian ad litem. However, while Mother cited to the rule in her issues presented

section and her statement of the case and statement of facts included a list of alleged

failures in the GAL’s performance, she failed to construct an argument to establish

how the listed facts, if true, violated the GAL’s duties, or how those alleged failures

required a modification of legal custody in her favor. Mother’s brief therefore fails

to meet the requirements of App.R. 16(A)(7) and an appellate court “is not obliged

to construct or develop arguments in support of an assignment of error where the

appellant has failed to do so.” Olive Oil, L.L.C. v. Cleveland Elec. Illum. Co., 2021-

Ohio-2309, ¶ 22 (8th Dist.).

Mother further claimed that the trial court relied upon erroneous

findings of facts and unsupported incompetent evidence. Mother has waived any challenge to the magistrate’s factual findings by failing to file objections to the

magistrate’s decision. Juv.R. 40(D)(3)(b)(iv).

Here, Mother requested modification of custody because she alleged

Father was neglecting S.N.A-K.’s medical care. A court may not modify a decree

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Related

In re A.L.
2013 Ohio 5120 (Ohio Court of Appeals, 2013)
In re E.R.P.
2012 Ohio 1053 (Ohio Court of Appeals, 2012)
Radford v. Radford
2011 Ohio 6263 (Ohio Court of Appeals, 2011)
In re E.B.
2020 Ohio 4139 (Ohio Court of Appeals, 2020)
In re A.B.
2021 Ohio 4613 (Ohio Court of Appeals, 2021)
Goldfuss v. Davidson
679 N.E.2d 1099 (Ohio Supreme Court, 1997)

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Bluebook (online)
2024 Ohio 4494, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-sna-k-ohioctapp-2024.