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State v. Bernard
| 3-25-06 | Constitutional Right to a Speedy Trial. Defendant-appellant's constitutional right to a speedy trial was not violated. | Miller | Crawford |
5/4/2026
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5/4/2026
| 2026-Ohio-1614 |
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State v. Tolliver
| 8-25-10 | Not Guilty By Reason Of Insanity (NGRI); Jury Instructions; Consecutive Sentences; R.C. 2929.14(C)(4); Firearm Specifications; R.C. 2929.14(B)(1)(b); R.C. 2941.1412(A); R.C. 2929.14(B)(1)(f). The trial court did not abuse its discretion by refusing to instruct the jury on the affirmative defense of NGRI since the evidence presented at trial was not sufficient to support an NGRI instruction. The trial court did not err by imposing consecutive sentences. The trial court made the appropriate R.C. 2929.14(C)(4) findings necessary to impose consecutive sentences and the record supports the trial court’s findings. The trial court did not err by imposing all four of the three-year firearm specifications because the conduct underlying each of the four counts of improperly discharging a firearm at or into a habitation was not committed as part of the same act or transaction. The trial court did not err by imposing 14 of the 16 seven-year firearm specifications concurrently. The trial court was required to impose two of the 16 seven-year firearm specifications that accompanied his felonious-assault convictions, and the trial court acted within its discretion by imposing the remaining 14 seven-year firearm specifications concurrently. | Zimmerman | Logan |
5/4/2026
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5/4/2026
| 2026-Ohio-1615 |
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Fikes v. Ohio Dept. of Rehab. & Corr.
| 9-25-29 | Civ.R. 12(B)(6); Motion to dismiss; Consumer Sales Practices Act; Statute of limitations. The trial court did not err in granting the motions to dismiss filed by the defendants-appellees. | Waldick | Marion |
5/4/2026
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5/4/2026
| 2026-Ohio-1616 |
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In re C.C.
| 11-25-07 | Permanent Custody; R.C. 2151.414. The trial court’s decision to grant permanent custody of the child to the agency is not against the manifest weight of the evidence. Clear and convincing evidence supports the trial court’s best-interest determination. The trial court did not err by continuing the agency’s temporary custody of the child beyond the passing of the sunset date since the problems that led to the original grant of temporary custody have not been resolved. | Zimmerman | Paulding |
5/4/2026
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5/4/2026
| 2026-Ohio-1617 |
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State v. Huffman
| 13-25-13 | Sufficient Evidence; Circumstantial Evidence; Ineffective Assistance of Counsel; Lay Witness. Circumstantial evidence can, by itself, be sufficient to support a conviction. To establish an ineffective assistance of counsel claim, the appellant must demonstrate that (1) defense counsel's performance was deficient and that (2) this deficient performance prejudiced the Defense. To preserve an issue for appeal, a party must raise a contemporaneous objection over the issue. This allows the trial court to have an opportunity to make a ruling and address the issue brought to its attention through the objection. | Willamowski | Seneca |
5/4/2026
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5/4/2026
| 2026-Ohio-1618 |
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Chambers v. Chambers
| 17-25-18 | Domestic Violence Civil Protection Order; Manifest Weight. When a respondent-appellant challenges a trial court's decision to issue a domestic violence civil protection order, the reviewing court will apply a manifest-weight-of-the-evidence standard on appeal. The appellant has the burden of establishing that the trial court erred. R.C. 3113.31(A)(1)(a)(ii) defines domestic violence. | Willamowski | Shelby |
5/4/2026
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5/4/2026
| 2026-Ohio-1620 |
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State v. Favorite
| 14-25-45 | Ineffective Assistance of Counsel; Crim.R. 11 Colloquy; Plea; Knowing, Voluntary, Intelligent. At a change of plea hearing, a defendant does not need to be informed of the specific sentence he or she will receive at sentencing in order for a plea to be knowing, voluntary, and intelligent. Rather, the defendant must be informed about what potential penalties are available for imposition at sentencing. | Willamowski | Union |
5/4/2026
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5/4/2026
| 2026-Ohio-1619 |
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State v. Gipple
| 4-25-11, 4-25-12, 4-25-13 | Jail Time Credit; Abuse of Discretion. The trial court did not abuse its discretion by denying defendant-appellant's motions to issue revised sentencing judgment entries to correct his jail-time credit. | Miller | Defiance |
4/27/2026
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4/27/2026
| 2026-Ohio-1517 |
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Larrick v. W&S Constr., L.L.C.
| 8-25-14 | More Definite Statement; 12(B)(6); 12(C); Motion to Dismiss; R.C. 4123.512; Civ.R. 8; Ward v. Kroger, 2005-Ohio-3560; Workers' Compensation. Plaintiff-Appellant did not object to the motion or order for more definite statement before the trial court; therefore, he waived his right to argue the more definite statement was wrongly ordered on appeal. The trial court did not err by granting Defendant-Appellee's motion to dismiss when Plaintiff-Appellant failed to specify a specific medical injury or condition in his pleadings. | Miller | Logan |
4/13/2026
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4/13/2026
| 2026-Ohio-1338 |
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State v. Grond
| 7-25-11 | Court Costs. Trial court did not err by imposing statutorily mandated court costs pursuant to R.C. 2947.23. | Waldick | Henry |
4/13/2026
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4/13/2026
| 2026-Ohio-1337 |
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In re J.H.
| 1-25-40 | R.C. 2151.414(D)(1); Permanent Custody; Best Interest; Manifest Weight of the Evidence; Motion for Extension. The trial court's decision granting the Agency permanent custody was supported by clear and convincing evidence. The trial court did not abuse its discretion by denying mother-appellant's motion for an extension. | Miller | Allen |
4/13/2026
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4/13/2026
| 2026-Ohio-1333 |
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State v. Myers
| 1-25-49 | R.C. 4511.19; Operating a Vehicle Impaired ("OVI"); Field sobriety tests; Reasonable suspicion; National Highway Traffic Safety Administration ("NHTSA") guidelines; Substantial compliance; Ohio Adm.Code Chapter 3701-53. The trial court did not err in overruling the motions to suppress filed by defendant-appellant. | Waldick | Allen |
4/13/2026
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4/13/2026
| 2026-Ohio-1334 |
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State v. Alqahtani
| 2-25-11 | Plain Error; Sufficiency of Evidence; Manifest Weight; Speeding; R.C. 4511.21(D). The conviction for speeding was not against the sufficiency or manifest weight of the evidence. No finding of plain error for admission of radar evidence. | Miller | Auglaize |
4/13/2026
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4/13/2026
| 2026-Ohio-1335 |
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State v. Long
| 3-25-17 | Crim.R. 7(D); Motion to amend indictment; Manifest weight of the evidence; Credibility of victims. The trial court erred in granting the state's motion to amend two counts of the indictment, as the amendment changed the identity of the crimes charged in those counts. Judgment of conviction and sentence reversed in part, affirmed in part. | Waldick | Crawford |
4/13/2026
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4/13/2026
| 2026-Ohio-1336 |
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State v. Houser
| 15-25-06 | Pre-sentence withdraw of no contest plea; Suppression; Search Warrant; Consent; Probable Cause; Cloud Data; Good-Faith Exception. The trial court did not abuse its discretion by denying the defendant-appellant’s presentence motion to withdraw his no-contest plea. The trial court properly denied the motion to suppress digital evidence obtained from the defendant-appellant's cell phone and corresponding cloud storage. The search warrant was sufficiently particular and supported by a sufficient nexus of probable cause. Alternatively, law enforcement executed the search in objectively reasonable good faith. | Zimmerman | Van Wert |
4/13/2026
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4/13/2026
| 2026-Ohio-1339 |
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In re R.C.
| 14-25-40; 14-25-41 | Suppression; Miranda; Custodial Interrogation; Voluntary Statement. The trial court did not err by denying R.G’s and R.C.’s motions to suppress statements made to law enforcement because Miranda warnings were unnecessary and their statements were voluntary. | Zimmerman | Union |
4/6/2026
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4/6/2026
| 2026-Ohio-1244 |
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State v. Meads
| 9-25-17, 9-25-18 | Motion to Seal Records of dismissed charges. Trial court erred by reviewing a motion to seal charges dismissed under R.C. 2953.32 rather than R.C. 2953.33. | Willamowski | Marion |
4/6/2026
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4/6/2026
| 2026-Ohio-1241 |
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State v. Meads
| 9-25-19 | Motion to Expunge. Trial court did not err in denying the motion to expunge when the victim objected and the movant presented no evidence in support. | Willamowski | Marion |
4/6/2026
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4/6/2026
| 2026-Ohio-1242 |
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State v. Montgomery
| 9-25-22 | Telecommunications harassment; R.C. 2917.21(A)(1); Motion to Dismiss; Personal Jurisdiction; Self Representation; Crim.R. 44(B); Petty Offense; Hybrid representation; Sufficiency of the Evidence; Continuance. Defendant-appellant’s telecommunications harassment conviction is based on sufficient evidence. The trial court did not err by denying the defendant-appellant’s motion to dismiss the complaint because the trial court had personal jurisdiction over the defendant-appellant since he voluntarily appeared and pleaded not guilty to the charge in the complaint. Defendant-appellant’s waiver of counsel was knowing, intelligent, and voluntary because the trial court substantially complied with the requirements of Crim.R. 44(B) by sufficiently inquiring in open court whether the defendant-appellant fully understood and relinquished his right to counsel. Standby counsel raising and arguing a Crim.R. 29 motion does not constitute improper hybrid representation. | Zimmerman | Marion |
4/6/2026
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4/6/2026
| 2026-Ohio-1243 |
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State v. Ochier
| 3-25-25 | Sentence; Prosecutorial Misconduct; Self-Defense; Ineffective Assistance of Counsel. Trial court considered the statutory factors and the sentence was within the statutory range, so is not reviewable. No prosecutorial misconduct because jury was advised to not consider the closing arguments. Jury's verdict regarding self-defense was not against the manifest weight of the evidence. Counsel was not ineffective as statements elicited were part of trial strategy. | Willamowski | Crawford |
4/6/2026
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4/6/2026
| 2026-Ohio-1238 |
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State v. Lochtefeld
| 8-25-18 | Driving Under Suspension; Weight of the Evidence; Effective Assistance of Counsel; Relevance of Evidence. The trial court did not err is excluding evidence of a valid license from another state when the statute states it is illegal to drive in Ohio if nonresident operating privileges had been suspended. Verdict was not against the manifest weight of the evidence. Defendant was not denied the effective assistance of counsel when the requested jury instruction was not a correct statement of law. | Willamowski | Logan |
4/6/2026
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4/6/2026
| 2026-Ohio-1240 |
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Urdiales v. Latin Am. Club of Defiance, Ohio
| 4-25-10 | Civ.R. 60(B); Hearing; Abuse of Discretion; Fraud upon the Court; Fraud upon a Party. To prevail on a Civ.R. 60(B) motion, the movant must demonstrate (1) that a meritorious claim or defense exists to be presented if relief from judgment is granted; (2) that one of the grounds listed in Civ.R. 60(B)(1)-(5) entitles the movant to relief; and (3) the timeliness requirements set forth in Civ.R. 60(B) have been satisfied. The movant cannot prevail without presenting operative facts that satisfy the three prongs of this test. Appellate courts review a trial court's decision on a Civ.R. 60(B) motion for relief from judgment under an abuse-of-discretion standard. While fraud upon an adverse party generally falls under the ground for relief set forth under Civ.R. 60(B)(3), fraud upon the court falls under the grounds for relief set forth under Civ.R. 60(B)(5). | Willamowski | Defiance |
4/6/2026
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4/6/2026
| 2026-Ohio-1239 |
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State v. Lammie
| 3-25-11 | Evidence of Prior Convictions for Impeachment Purposes; Evid.R. 609(B); Abuse of Discretion; Limiting Instruction; Merger; R.C. 2941.25; Plain Error. The trial court did not abuse its discretion when it admitted evidence of the defendant-appellant’s prior convictions. The prior convictions are within the ten-year time limit and involve crimes of dishonesty and moral turpitude. Defense counsel’s decision not to request a limiting instruction regarding the jury’s use of the defendant-appellant’s prior convictions can be a tactical one. Trial courts should not interfere with the tactical decisions of defense counsel by stepping in and sua sponte giving a limiting instruction. Therefore, the trial court did not commit plain error by failing to sua sponte give a limiting instruction. The defendant-appellant cannot establish the first element of the plain-error test—that an error occurred—because the trial court did not err by sentencing the defendant-appellant on the felonious-assault and domestic-violence convictions. | Zimmerman | Crawford |
3/30/2026
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3/30/2026
| 2026-Ohio-1109 |
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State v. Fails
| 1-25-23 | Sufficiency of the Evidence; Manifest Weight of the Evidence; Ineffective Assistance of Counsel. The defendant-appellant’s obstructing-official-business and resisting-arrest convictions are based on sufficient evidence and are not against the manifest weight of the evidence. The decision of the defendant-appellant’s trial counsel to cross-examine a witness without the use of the transcript of the hearing is trial strategy and does not constitute ineffective assistance of counsel. | Zimmerman | Allen |
3/30/2026
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3/30/2026
| 2026-Ohio-1107 |
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State v. Garee
| 1-25-45 | Sufficiency; Manifest Weight; Collateral Attack. Prior judgment entries sufficiently established that defendant had pleaded guilty to, or been convicted of, 5 prior Operating a Vehicle Impaired ("OVI")s within 20 years. Collateral attack on prior plea for being uncounseled not supported by the evidence. | Waldick | Allen |
3/30/2026
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3/30/2026
| 2026-Ohio-1108 |
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State v. Davis
| 9-25-07 | Post-Sentence Motion to Withdraw a Plea; Manifest Injustice; Crim.R. 32; Hearing.1. When a defendant is represented by an attorney and is not proceeding pro se, defense counsel is to make motions. If a motion to withdraw a plea is made after a sentence has been pronounced, the legal standard governing post-sentence motions to withdraw a plea is applicable even if the sentencing entry has not yet been issued. Under Crim.R. 32.1, a trial court may grant a post-sentence motion to withdraw a plea to correct a manifest injustice. | Willamowski | Marion |
3/30/2026
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3/30/2026
| 2026-Ohio-1110 |
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State v. Caudill
| 17-25-14, 17-25-15 | Mootness of Appeal. The appeal is moot because the defendant-appellant voluntarily completed her jail term and her community control was terminated. | Miller | Shelby |
3/30/2026
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3/30/2026
| 2026-Ohio-1111 |
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State v. Ross
| 14-25-35 | Community Control Violation; Substantial Evidence; Confrontation of Witnesses; Due Process. The trial court did not err by finding that substantial evidence supported a finding that defendant-appellant violated the terms of his community control. The trial court did not violate defendant-appellant's due-process rights at his community-control revocation hearing. | Miller | Union |
3/23/2026
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3/23/2026
| 2026-Ohio-989 |
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State v. Payne
| 13-25-16 | Manifest Weight; Sentencing. Conviction for Gross Sexual Imposition was not against the weight of the evidence. Further, sentence was not based on improper considerations. | Waldick | Seneca |
3/23/2026
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3/23/2026
| 2026-Ohio-988 |
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Vaco, L.L.C. v. Semco Inc.
| 9-25-20 | Summary Judgment; Weight of the Evidence, Breach of Contract; Fraud; Control of Docket. Trial court erred in granting summary judgment on the breach of contract claim when there was a genuine issue of material fact as to the terms of the oral contract and as to whether plaintiff completed the contract. The trial court correctly granted summary judgment on the fraud claim when defendant could not show justifiable reliance. Trial court did not abuse its discretion when it denied the motion for a third extension of the discovery deadline. | Willamowski | Marion |
3/23/2026
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3/23/2026
| 2026-Ohio-986 |
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State v. Jones
| 9-25-24 | Sufficient Evidence; Manifest Weight; Self-Defense Instruction. To secure a jury instruction on self-defense, the Defense must produce evidence that tends to support the conclusion that he or she used force in self-defense. This involves producing evidence from which each of the elements of self-defense could be found. The elements of self-defense are cumulative; thus, the failure to establish one element means that this affirmative defense is not successfully raised. To establish a conviction for assault in violation of R.C. 2903.13(A), the State must prove that the defendant knowingly caused or attempted to cause physical harm to another. The slightest injury is sufficient to establish physical harm in this analysis. | Willamowski | Marion |
3/23/2026
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3/23/2026
| 2026-Ohio-987 |
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State v. Allen
| 9-25-21 | Sufficiency; Manifest Weight. Defendant properly convicted of Engaging in a Pattern of Corrupt Activity and Trafficking offenses. Errors during sentencing require new sentencing hearing. | Waldick | Marion |
3/16/2026
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3/16/2026
| 2026-Ohio-884 |
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Young v. Young
| 5-24-52 | Marital Residence; Equalization Payment; Spousal Support; Child Support; Exclusion of Evidence. A trial court's classification of property as marital or separate is a factual determination and is reviewed under a manifest weight standard. R.C. 3105.18 directs trial courts to consider the matter of spousal support after determining the division of property between the parties. A separation agreement is a contract between two parties. However, once a separation agreement is incorporated into a court order, the obligations therein are not imposed by contract but by decree. R.C. 3105.171(F) contains factors that a trial court is to consider in dividing marital property. | Willamowski | Hancock |
3/16/2026
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3/16/2026
| 2026-Ohio-883 |
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State v. Freed
| 6-25-15 | Presentence motion to withdraw guilty plea. Crim.R. 32.1. The trial court abused its discretion by denying the defendant-appellant’s presentence motion to withdraw his guilty pleas without conducting a hearing. | Zimmerman | Hardin |
3/9/2026
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3/9/2026
| 2026-Ohio-767 |
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State v. Upkins
| 17-24-12 | Manifest Weight; Possession of Drugs; Credibility of Witnesses; Prosecutorial Misconduct; Right to a Fair Trial; Due Process of Law; Plain Error; Ineffective Assistance of Counsel. Defendant-appellant's possession-of-drugs convictions are not against the manifest weight of the evidence. Even assuming the prosecutor's comments during opening statements and closing arguments were inappropriate, the trial court did not commit plain error in allowing them. Defendant-appellant failed to demonstrate that he received ineffective assistance of counsel. | Miller | Shelby |
3/9/2026
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3/9/2026
| 2026-Ohio-770 |
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State v. Myers
| 16-25-09; 16-25-10 | Consecutive Sentences; R.C. 2929.14(C)(4). The trial court made the appropriate R.C. 2929.14(C)(4) findings necessary to impose consecutive sentences and the record supports the trial court’s findings. | Zimmerman | Wyandot |
3/9/2026
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3/9/2026
| 2026-Ohio-769 |
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Cole v. Schoenberger
| 13-25-17 | Bench Trial; Manifest Weight of the Evidence; Pro Se Appellant; App.R. 16(A)(3). The defendant-appellant’s brief is deficient in that it fails to set forth a statement of the assignments of error presented for review as required by App.R. 16(A)(3). Additionally, many of the arguments contained in the defendant-appellant’s brief are indecipherable and unsupported by any basis in the law. In the interest of resolving cases on the merits, we will construe the defendant-appellant’s arguments as a requests that we reverse the trial court’s decision as being against the manifest weight of the evidence. Based on our review of the record, we conclude that the trial court’s decision to grant, in part, the plaintiff-appellee’s complaint for declaratory relief is not against the manifest weight of the evidence. We further conclude that the trial court had competent, credible evidence before it on which to base its decision. | Zimmerman | Seneca |
3/3/2026
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3/9/2026
| 2026-Ohio-768 |
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State v. Shefbuch
| 17-25-08 | Felony sentencing review; R.C. 2953.08; R.C. 2929.11; R.C. 2929.12. Defendant-appellant's prison sentence is not clearly and convincingly contrary to law. | Miller | Shelby |
3/2/2026
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3/2/2026
| 2026-Ohio-708 |
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In re K.W.
| 3-25-18, 3-25-19, 3-25-20 | Permanent Custody; R.C. 2151.414. Clear and convincing evidence supports the trial court’s finding that the children cannot be placed with either parent within a reasonable period of time or should not be placed with either parent, and that it was in the children’s best interest that the agency be granted permanent custody. | Zimmerman | Crawford |
3/2/2026
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3/2/2026
| 2026-Ohio-707 |
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Zeedyk v. 5C’s Drying
| 4-25-05 | Contract Formation; Oral Contract; Implied-in-Fact Contract; Meeting of the Minds; Breach of Contract; Manifest Weight of the Evidence; Foreclosure; Promissory Note; Want of Consideration; Attorney Fees; Segregation of Fees. The trial court properly granted judgment in foreclosure on the plaintiffs’ promissory note because there is some competent, credible evidence that the defendants failed to carry their burden to prove a want of consideration. The trial court did not err by determining that no enforceable contract existed regarding the sale of a hauling business—either express or implied-in-fact—because some competent, credible evidence demonstrated that the parties formed an enforceable contract. The trial court abused its discretion by awarding the plaintiffs the full amount of their requested attorney fees without segregating the costs associated with the fee-shifting foreclosure claim from those incurred in litigating the unrelated contract disputes. | Zimmerman | Defiance |
2/23/2026
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2/23/2026
| 2026-Ohio-618 |
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State v. Pope
| 9-25-23 | Suppression; No Contest Plea; PRC. Trial counsel was not ineffective for failing to file a more comprehensive suppression motion. Appellant did not demonstrate plea was in violation of Crim.R. 11, but trial court did fail to mention PRC at sentencing hearing. | Waldick | Marion |
2/23/2026
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2/23/2026
| 2026-Ohio-619 |
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Copeland Corp., L.L.C. v. Travelers Cas. & Sur. Co.
| 17-25-11 | Declaratory judgment; summary judgment; choice of law; single vs. multiple occurrences. The trial court did not err in determining that Ohio law was applicable to the contract dispute between the parties, nor did the trial court err in holding that the underlying asbestos claims constituted multiple occurrences. | Waldick | Shelby |
2/17/2026
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2/17/2026
| 2026-Ohio-525 |
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In re A.D.
| 14-25-27 | Legal Custody; Manifest Weight; Ineffective Assistance of Counsel. Trial court's decision to grant legal custody of A.D. to the paternal aunt was supported by the evidence and was reasonably in the best interest of the child. Counsel for father was not ineffective when there is nothing to show that the outcome would have been different if counsel had presented the evidence father wanted. | Willamowski | Union |
2/17/2026
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2/17/2026
| 2026-Ohio-524 |
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State v. Alexander
| 5-25-25 | Felonious Assault; Self-Defense; Manifest Weight of the Evidence. The jury did not lose its way in rejecting the defendant-appellant’s claim of self-defense and the felonious-assault conviction is not against the manifest weight of the evidence. | Zimmerman | Hancock |
2/17/2026
|
2/17/2026
| 2026-Ohio-522 |
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State v. Brady
| 9-24-65 | Manifest Weight; Aggravated Murder; Prior Calculation and Design. Defendant-appellant's aggravated murder conviction is not against the manifest weight of the evidence. | Miller | Marion |
2/17/2026
|
2/17/2026
| 2026-Ohio-523 |
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State v. Burns
| 1-25-06 | Confrontation Clause; Due Process; Juvenile Bindover Hearing. The trial court did not violate defendant-appellant’s right to confront witnesses by admitting hearsay testimony at the juvenile bindover hearing. | Miller | Allen |
2/17/2026
|
2/17/2026
| 2026-Ohio-544 |
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State v. McLellan
| 1-24-61 | Speedy Trial; R.C. 2945.71; R.C. 2945.72; R.C. 2945.73; Sufficiency of Evidence; Manifest Weight; Possession of Drugs. Defendant-appellant’s constitutional right to a speedy trial was not violated. Defendant-appellant’s possession-of-drugs convictions are supported by sufficient evidence and are not against the manifest weight of the evidence. | Miller | Allen |
2/9/2026
|
2/9/2026
| 2026-Ohio-402 |
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In re P.S.
| 1-25-15, 1-25-16, 1-25-20 | Permanent Custody. Trial court did not err by granting permanent custody of the parties' children to children's services agency. | Waldick | Allen |
2/9/2026
|
2/9/2026
| 2026-Ohio-403 |
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State v. Metzger
| 1-25-19 | Aggravated Trafficking in Drugs; Engaging in a Pattern of Corrupt Activity; Sufficiency of the evidence; Manifest weight of the evidence; Warrantless search of vehicle; Cross-examination of witness; Qualifying a witness as an expert. The judgment of conviction and sentence is affirmed. | Waldick | Allen |
2/9/2026
|
2/9/2026
| 2026-Ohio-404 |
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Whitman v. Whitman
| 8-24-47 | Calculation of Child Support; Abuse of Discretion; Contempt; Void Purge Condition; R.C. 3105.171(I); Allocation of Tax Exemption; R.C. 3119.82. In this post-decree proceeding, the trial court did not abuse its discretion in the calculation of child support. The mother-appellee was employed to full capacity and a deviation was warranted after consideration of the factors set forth in R.C. 3119.23. The trial court did not abuse its discretion by finding the father-appellant in contempt and imposing penalties for the contempt. The trial court’s award of attorney fees in excess of $400 is an abuse of discretion. A local rule of court limits reasonable fees to $400 in the absence of professional testimony post-decree actions involving contempt. The trial court’s purge condition requiring the father-appellant to comply with all court orders in the future is void because it does not properly allow the contemnor to purge the contempt. The trial court did not modify the terms of the parties’ divorce decree in violation of R.C. 3105.171(I). The trial court did not abuse its discretion by admitting evidence that was properly authenticated. The trial court’s allocation of the tax emption to the nonresidential parent without any consideration of the child’s best interest and the factors set forth in R.C. 3119.82 is an abuse of discretion. | Zimmerman | Logan |
2/9/2026
|
2/9/2026
| 2026-Ohio-406 |
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