C.L. v. J.K., 2017 Ohio 1024

Father (J.K.) and Mother divorced in 2005; Mother is the residential parent and sole custodian of two minor children.
In 2015 Father, proceeding pro se, moved to modify the allocation of parental rights and sought contempt against Mother; the magistrate conducted four hearings.
The magistrate denied modification and contempt, and the trial court adopted the magistrate’s decision; Father filed objections that were overruled.
Father appealed, alleging the trial court relied on "clearly erroneous" factual findings and raising numerous other accusations against the judge and magistrate.
The appellate court found Father’s brief procedurally deficient for failing to apply law to facts and for not complying with App.R. 16(A)(7); it declined to develop his arguments and affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the magistrate/trial court made clearly erroneous factual findings supporting denial of modification and contempt	Father argued the court’s findings were clearly erroneous and thus the decision was an abuse of discretion	Mother implicitly defended the magistrate’s findings and the trial court’s adoption (court record supported decision)	Court declined to address merits because Father failed to adequately develop the argument; judgment affirmed
Whether appellate court may consider Father’s allegations of judicial corruption/criminal conduct	Father urged the court to investigate judges, disbar them, and pursue criminal charges	Court noted lack of jurisdiction to adjudicate judicial-conduct or criminal matters on appeal and that appellate relief is limited by statute	Court refused to entertain those claims and explained it lacked authority to initiate such investigations or proceedings

Kremer v. Cox, 114 Ohio App.3d 41 (9th Dist. 1996) (failure to comply with appellate practice rules is ordinarily fatal and pro se litigants remain subject to the same procedural rules)