A.B. v. I.E., 2024 Ohio 1809

A.B. (appellee) and I.E. (appellant), the parents of an infant son, had a tumultuous relationship marked by several incidents of alleged aggressive and erratic behavior by I.E., including during cohabitation in Michigan and joint travel.
After multiple escalating incidents—some involving threats, physical force, and restricting A.B.'s ability to comfort or breastfeed their child—A.B. left I.E. and returned to Ohio with their son.
Upon separation, I.E. engaged in harassing conduct including unannounced visits to A.B.’s parents’ home in Ohio, sending numerous frantic messages, and triggering fruitless abuse and fraud investigations against A.B. and her family.
A.B. requested a civil protection order (CPO) for herself and her son, citing several specific aggressive incidents supported by audio recordings.
After a March 2023 evidentiary hearing, the trial court granted the CPO under Ohio’s domestic violence statute, R.C. 3113.31, leading to I.E.'s appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether CPO should have been granted under R.C. 3113.31	A.B. argued that I.E. engaged in a pattern of domestic violence and threatening, erratic conduct placing her and their son in fear of harm, supported by testimony and recordings.	I.E. contended the incidents did not constitute domestic violence and challenged the fairness of the proceedings, instead blaming A.B. for relationship issues.	The appellate court upheld the CPO, finding the trial court had credible, competent evidence of domestic violence and no abuse of discretion.

Felton v. Felton, 79 Ohio St.3d 34 (Ohio 1997) (CPOs must be supported by a preponderance of the evidence showing petitioner and/or household members are in danger of domestic violence; appellate review is for abuse of discretion)
Blakemore v. Blakemore, 5 Ohio St.3d 217 (Ohio 1983) (Defines abuse of discretion as an attitude that is unreasonable, arbitrary, or unconscionable; establishes standard of review for appellate courts)