State ex rel. Knox v. Gallagher

CourtOhio Court of Appeals
DecidedJune 16, 2026
DocketWM-26-002
StatusPublished

This text of State ex rel. Knox v. Gallagher (State ex rel. Knox v. Gallagher) 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
State ex rel. Knox v. Gallagher, (Ohio Ct. App. 2026).

Opinion

[Cite as State ex rel. Knox v. Gallagher, 2026-Ohio-2345.]

IN THE COURT OF APPEALS OF OHIO SIXTH APPELLATE DISTRICT WILLIAMS COUNTY

STATE EX REL. LEO PATRICK COURT OF APPEALS NO. {86}WM-26-002 KNOX AND SHANNON MARIE KNOX

RELATORS

V.

THE HONORABLE KAREN K. GALLAGHER

RESPONDENT

DECISION AND JUDGMENT

Decided: June 16, 2026

***** Anaya N. Khan, for relators.

Mark R. Weaver, Ryan C. Spitzer, and Andrew Fraser, for respondent. *****

MAYLE, J.

{¶ 1} This case is before the court on the March 12, 2026 motion to dismiss filed

by respondent, Judge Karen Gallagher of the Williams County Court of Common Pleas,

Juvenile Division. Because Judge Gallagher included information from outside of the

pleadings with her motion, on March 25, 2026, we converted the motion to a motion for

summary judgment and gave her and relators, Leo Knox and Shannon Knox, time to file evidence that complies with Civ.R. 56.1 Both parties filed memoranda in response to our

order. The motion for summary judgment is now decisional. Because the Knoxes cannot

show that they are entitled to the requested writs, we grant Judge Gallagher’s motion.

{¶ 2} Also before the court is the March 27, 2026 motion for leave to intervene

filed by Ina O’Briant, guardian for L.K., mother of the child involved in the underlying

dependency case. On March 30, 2026, the Knoxes filed a memorandum in support of

O’Briant’s motion for leave to intervene. Because we are granting Judge Gallagher’s

motion for summary judgment and dismissing this case, we deny O’Briant’s motion for

leave to intervene.

{¶ 3} The final motion pending before the court is the Knoxes’ May 27, 2026

“EMERGENCY MOTION TO EXCLUDE RESPONDENT’S UNSERVED MAY 13,

2026 SUPPLEMENTAL SUMMARY-JUDGMENT SUBMISSION, TO REQUIRE

PROOF OF SERVICE, AND FOR CONDITIONAL SHOW-CAUSE AND

SANCTIONS RELIEF.” On May 29, 2026, Judge Gallagher filed a response to the

Knoxes’ motion, and on June 1, 2026, the Knoxes filed a reply in support of their motion.

Because the Knoxes are not entitled to file a response to Judge Gallagher’s supplemental

summary judgment memorandum and cannot show that they were prejudiced by Judge

Gallagher’s inadvertent failure to serve her supplemental memorandum, we deny their

motion to exclude.

1 The clerk of court did not serve the parties our order converting the motion to dismiss, so we reissued the order on April 29, 2026. 2. {¶ 4} In Judge Gallagher’s motion, she raises three arguments in support of her

motion to dismiss the Knoxes’ complaint for writs of mandamus and procedendo. First,

she argues that the Knoxes lack standing to bring their complaint because they are not

parties to the underlying juvenile court case. Next, she argues that the Knoxes’ motions

are not ripe for review until the foreign child-custody determination is registered and

confirmed under R.C. 3127.35, which has not yet happened. Finally, even if the Knoxes

correctly filed to register the foreign child-custody determination, there is a 30-day

window for contesting the registration that has not yet passed, so the child-custody

determination cannot yet be registered and confirmed. For all of these reasons, Judge

Gallagher argues that the Knoxes have no legal right to the relief they are seeking, and

she has no legal duty to grant it.

1. Summary judgment standard

{¶ 5} We can grant a motion for summary judgment only when the moving party

demonstrates:

(1) that there is no genuine issue as to any material fact; (2) that the moving party is entitled to judgment as a matter of law; and (3) that reasonable minds can come to but one conclusion, and that conclusion is adverse to the party against whom the motion for summary judgment is made, who is entitled to have the evidence construed most strongly in his favor.

Harless v. Willis Day Warehousing Co., 54 Ohio St.2d 64, 66 (1978); Civ.R. 56(C).

{¶ 6} The party seeking summary judgment must specifically delineate the basis

upon which the motion is brought and identify those portions of the record that

demonstrate the absence of a genuine issue of material fact. Dresher v. Burt, 75 Ohio

3. St.3d 280, 293 (1996); Mitseff v. Wheeler, 38 Ohio St.3d 112 (1988), syllabus. When a

properly supported motion for summary judgment is made, an adverse party may not rest

on mere allegations or denials in the pleadings but must respond with specific facts

showing that there is a genuine issue of material fact. Civ.R. 56(E); Riley v.

Montgomery, 11 Ohio St.3d 75, 79 (1984). The opposing party must do so using

“pleadings, depositions, answers to interrogatories, written admissions, affidavits,

transcripts of evidence, and written stipulations of fact . . . .” Civ.R. 56(C). A “material”

fact is one that would affect the outcome of the suit under the applicable substantive law.

Russell v. Interim Personnel, Inc., 135 Ohio App.3d 301, 304 (6th Dist. 1999); Needham

v. Provident Bank, 110 Ohio App.3d 817, 827 (8th Dist. 1996), citing Anderson v. Liberty

Lobby, Inc., 477 U.S. 242, 248 (1986).

2. Standing

{¶ 7} Judge Gallagher first argues that the Knoxes lack standing to bring their

mandamus and procedendo complaint. She contends that they do not have a beneficial

interest in the underlying dependency proceedings because they are not parties to the

dependency case.

{¶ 8} The Knoxes respond that the correct beneficial-interest inquiry is whether

they would be directly benefited or injured by a judgment in the underlying case. They

claim that they would. They alleged in their complaint that Michigan made them the

child’s guardians, they filed the guardianship papers in the juvenile court case and sought

enforcement of the foreign child-custody determination, and “unresolved motions

prevented any judicial determination on participation and enforcement before the court

4. proceeded toward immediate placement decisions.” They contend that these allegations

show the direct legal stake necessary to give them standing to pursue these mandamus

and procedendo claims. The Knoxes also point out that Judge Gallagher should not be

able to ignore her duty to rule on pending motions and then point to their nonparty status

(which they imply only exists because Judge Gallagher has not yet ruled on their motion

to intervene) to claim they lack standing. Finally, the Knoxes argue that “Ohio law does

not permit a court to defer the threshold ruling, allow the resulting exclusion to persist,

and then invoke that exclusion as the reason no one may obtain review of the failure to

rule.”

{¶ 9} In her reply, Judge Gallagher argues that the Knoxes lack standing to bring

their mandamus claim because R.C. 2731.02, the mandamus statute, says that mandamus

“may issue on the information of the party beneficially interested” and the Knoxes are

not parties to the underlying juvenile court case. (Emphasis added.) She also claims that

the cases the Knoxes cite in support of their position do not establish that they have

standing.

{¶ 10} A person lacks standing unless he or she has, in an individual or

representative capacity, “some real interest in the subject matter of the action.” State ex

rel. Dallman v. Franklin Cty. Court of Common Pleas, 35 Ohio St.2d 176 (1973),

syllabus.

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State ex rel. Knox v. Gallagher, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-ex-rel-knox-v-gallagher-ohioctapp-2026.