Kamp v. Figuero

2025 Ohio 4325
CourtOhio Court of Appeals
DecidedSeptember 15, 2025
Docket2024-L-090
StatusPublished

This text of 2025 Ohio 4325 (Kamp v. Figuero) 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
Kamp v. Figuero, 2025 Ohio 4325 (Ohio Ct. App. 2025).

Opinion

[Cite as Kamp v. Figuero, 2025-Ohio-4325.]

IN THE COURT OF APPEALS OF OHIO ELEVENTH APPELLATE DISTRICT LAKE COUNTY

KATIE KAMP, CASE NO. 2024-L-090

Petitioner-Appellee, Civil Appeal from the - vs - Court of Common Pleas

ASHLEY FIGUERO, Trial Court No. 2024 CS 001682 Respondent-Appellant.

OPINION AND JUDGMENT ENTRY

Decided: September 15, 2025 Judgment: Affirmed

Daniel J. Williams, Dworken & Bernstein Co., LPA, 60 South Park Place, Painesville, OH 44077 (For Petitioner-Appellee).

Ashley Figuero, pro se, 3125 Chapel Road, Ashtabula, OH 44004 (Respondent- Appellant).

ROBERT J. PATTON, P.J.

{¶1} Appellant, Ashley Figuero (“Figuero”), appeals from the judgment of the

Lake County Court of Common Pleas, adopting the magistrate’s agreed consent order

between Figuero and appellee, Katie Kamp (“Kamp”). For the following reasons, we

affirm.

{¶2} This case arose from a relationship that developed between Kamp’s minor

daughter and Figuero’s minor son. During the eight-month relationship, Kamp’s daughter

told Figuero that Kamp was neglecting her. Kamp’s daughter wanted to move in with

Figuero and her son. Figuero began calling the daughter’s school to inquire about her attendance and contacted Kamp’s employer regarding Kamp’s past discipline at work.

Figuero texted Kamp and her extended family repeatedly demanding that the son and

daughter be allowed to contact each other.

{¶3} Kamp filed a motion for an ex parte civil stalking protection order (“CSPO”)

against Figuero with the Lake County Court of Common Pleas on October 30, 2024. An

ex parte hearing was held the same day. Kamp explained to the trial court that she feared

that Figuero would come to her child’s school and take her. Kamp alleged that Figuero

made threats to attempt to gain custody of Kamp’s daughter. The trial court granted the

temporary CSPO against Figuero, but only with respect to preventing contact between

Figuero and Kamp’s daughter. The motion was granted based on Kamp’s fear for her

daughter, and the matter was scheduled for a full hearing to be held on November 13,

2024.

{¶4} Figuero filed for a reciprocal CSPO against Kamp in a separate case. Prior

to the full hearing on Kamp’s CSPO, Kamp hired an attorney who reached out to Figuero

with a proposed consent agreement. Kamp’s attorney explained, among other terms

included, pursuant to the agreement Figuero would consent to the CSPO and drop the

reciprocal CSPO filed against Kamp. Figuero agreed to the terms presented by Kamp’s

attorney, and the proposed order was presented to the trial court at what would have been

the full hearing, on November 13, 2024. The trial court addressed Figuero about her

understanding of the agreement. The trial court offered Figuero additional time to review

the agreement, which she accepted. After reviewing the agreement, Figuero indicated to

the trial court that she understood and agreed to its terms. The magistrate explained the

quasi-criminal nature of the terms of the consent order, and that if she violated the order

PAGE 2 OF 6

Case No. 2024-L-090 by contacting Kamp or anyone in her household, she could face criminal penalties.

Figuero indicated that she understood and agreed. Figuero signed the agreement. The

agreement was accepted through a magistrate’s order which was adopted by the trial

court the same day, on November 13, 2024. Figuero now appeals to this Court asserting

that the trial court improperly failed to make findings of fact prior to granting the CSPO,

and that the evidence presented was insufficient to support the issuance of a CSPO.

Figuero further contends that the trial court erred in allowing her to enter into the

agreement without fully understanding its terms regarding interaction between her son

and Kamp’s daughter.

{¶5} We conclude, after a thorough review of the record and pertinent law, that

Figuero waived her ability to claim error on appeal when she entered into the consent

CSPO agreement and is now barred from asserting error.

Assignments of Error

{¶6} On appeal, Figuero asserts three assignments of error:

{¶7} “[1.] The Trial Court erred in issuing the Civil Protection Order: Violation of

First Amendment Rights of [t]he United States Constitution. The Trial Court’s ruling

issuing the temporary protection order on October 30th, 2024 was contrary to law and in

violation of Appellant’s First Amendment Rights to freedom of speech. Reporting child

and elderly abuse, neglect, or exploitation is a legal obligation under Ohio Revised Code

and falls under Appellant’s First Amendment Rights to freedom of speech.”

{¶8} “[2.] The Trial Court erred in elucidating the type of voluntary communication

to be expected or allowed between Appellee and Appellant’s minor children, when the

Appellant sought understanding. The Trial Court not addressing Appellant’s concerns for

PAGE 3 OF 6

Case No. 2024-L-090 when and how the minor children may have communication again was contrary to law

and in violation of due process; Appellant’s Fourteenth Amendment Rights.”

{¶9} “[3.] The trial court violated the Appellant’s due process rights by failing to

apply the correct legal standard under Ohio Revised Code § 2903.211, which requires

evidence of a pattern of conduct that knowingly causes another person to believe they

will suffer physical harm or mental distress; not to simply support a parent’s desire to

prevent communication without evidence of a physical threat[.]”

Temporary Protection Order

{¶10} Under Figuero’s first assignment of error, she asserts that the trial court

erred in issuing the temporary protection order. This Court has previously noted: “[A]n ex

parte order is always temporary and thus, by definition, is not final and appealable.” Palo

v. Palo, 2004-Ohio-5638, ¶ 14 (11th Dist.) (determining that pursuant to R.C.

3113.33(D)(1) CPO is a temporary protection order is not a final appealable order).

Accordingly, as Figuero’s first assignment of error relates to the ex parte order, we decline

to address this issue.

CSPO Consent Order

{¶11} Figuero’s second and third assignments of error raise issues with the terms

of the CSPO consent order as it relates to communication between the parties’ minor

children, and whether the trial court made the requisite findings prior to issuing the order.

The Fifth District Court of Appeals has weighed in on whether a CSPO consent agreement

can be challenged on appeal:

Consent orders such as the one in this case, are authorized in the context of civil protection orders issued pursuant to R.C. 2903.214. Harris v. Miami Cty. Sherriff’s Dept., 160 Ohio App.3d 435, 2005-Ohio-827 N.E.2d 807, ¶ 17; State v. Myers,

PAGE 4 OF 6

Case No. 2024-L-090 10th Dist. Franklin No. 09AP-212, 2009-Ohio-4659, 2009 WL 2872977, ¶ 2[.] We will not interfere with the clear and unambiguous agreement of the parties based upon the appellant’s change of heart regarding the terms of the consent order. The Supreme Court of Ohio has noted that “[f]rom early in this state’s history, we have held that a party participating in a consent judgment will not be allowed to appeal errors from that judgment. Wells v. Warrick Martin & Co. (1853), 1 Ohio St. 386, paragraph one of the syllabus; Jackson v. Jackson (1865), 16 Ohio St. 163, paragraph one of the syllabus, citing Wells, supra. Sanit.

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Related

Harris v. Miami County Sheriff's Department
827 N.E.2d 807 (Ohio Court of Appeals, 2005)
Palo v. Palo, Unpublished Decision (10-22-2004)
2004 Ohio 5638 (Ohio Court of Appeals, 2004)
Windsor v. Bristow
2018 Ohio 1020 (Ohio Court of Appeals, 2018)
Sanitary Commercial Services, Inc. v. Shank
566 N.E.2d 1215 (Ohio Supreme Court, 1991)

Cite This Page — Counsel Stack

Bluebook (online)
2025 Ohio 4325, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kamp-v-figuero-ohioctapp-2025.