A.F. v. R.A.T., 2021 Ohio 2568

On Dec. 2, 2019, a minor (A.F.), through his father, obtained an ex parte domestic-violence civil protection order (CPO) against his mother (R.A.T.) and stepfather (R.M.T., Sr.).
A full hearing occurred on Dec. 10, 2019; the trial court issued CPOs against both respondents effective through Dec. 9, 2020.
Appellants R.A.T. and R.M.T., Sr. appealed; the appeals were consolidated in this court.
Appellants raised three assignments: lack of findings of fact, inability to prepare a defense due to time/document constraints, and that evidence was not considered before granting a one-year CPO.
The court reviewed mootness sua sponte because the CPOs expired in December 2020 and appellants did not assert demonstrated legal collateral consequences.
Applying recent Ohio precedent, the court concluded the appeals were moot and dismissed them.

Issue	A.F.'s Argument	R.A.T./R.M.T.'s Argument	Held
Whether an appeal from an expired domestic-violence CPO is moot	The CPO was valid and no relief was required beyond its term (appellee implicitly urged dismissal on mootness grounds)	The CPOs should be reversed or vacated due to procedural errors (no findings, inadequate time to defend, evidence ignored)	Appeal dismissed as moot because the CPOs expired and appellants failed to demonstrate legal collateral consequences sufficient to invoke the collateral-consequences exception

Cyran v. Cyran, 152 Ohio St.3d 484 (Ohio 2018) (held that an expired domestic-violence CPO does not satisfy the collateral-consequences exception absent demonstrated legal collateral consequences)
Wilder v. Perna, 174 Ohio App.3d 586 (8th Dist. 2007) (applied the collateral-consequences exception to an expired CPO)