C.R. v. Headley, 2025 Ohio 1745

C.R. filed a petition for a Civil Protection Order (CPO) against her former partner, Headley, alleging severe domestic violence on July 7, 2023, and ongoing threatening behavior.
C.R. had previously obtained a Temporary Protection Order (TPO) in an associated criminal case against Headley related to the same incident.
At the CPO hearing, C.R. was prevented from completing her testimony or introducing other witnesses or evidence.
The trial court dismissed the petition, stating it was facially deficient and did not allege recent enough threats or violence to justify a CPO.
C.R. appealed, arguing that the court denied her due process by cutting off the hearing and wrongly assessed the sufficiency of her petition.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the TPO negated the need or possibility for a civil CPO	TPO was no longer in effect once ex parte CPO issued; a CPO was still needed	TPO still effective so CPO unnecessary	Court's denial was not based on TPO existence; no error
Sufficiency of C.R.'s CPO petition	Petition satisfied all statutory elements with detailed allegations of abuse	Petition facially deficient; threats not recent enough	Petition met legal requirements; trial court erred
Right to a full hearing	Court denied C.R. due process by ending testimony early, precluding evidence	Not specified	C.R. was denied a full hearing and due process; trial court erred
Dismissal before completion of case-in-chief	Court granted defense motion to dismiss prematurely	Threats too old; no new evidence alleged	Dismissing before full hearing was plain error

Tarini v. Tarini, 2012-Ohio-6165 (full hearing on CPO requires opportunity for all evidence and argument)
Deacon v. Landers, 68 Ohio App.3d 26 (defining "full hearing" in protection order proceedings)
Goldfuss v. Davidson, 79 Ohio St.3d 116 (plain error in civil context only for errors seriously affecting fairness/integrity of judicial process)