Cornell v. Hatfield, 2018 Ohio 549

Petitioner Ashley Cornell sought a domestic violence civil protection order (DVCPO) against her ex‑boyfriend Nicholas Hatfield after he allegedly confronted her fiancé, Jamie Mallow, at Mallow’s workplace and threatened to kill Cornell and others and to break into their home.
The trial court issued an ex parte DVCPO and set a full hearing.
At bench hearings, Mallow testified that Hatfield was highly agitated and threatened to "kick the door down" and "take out" anyone in his way, including Mallow’s children and Cornell’s parents; Cornell testified she feared for her household’s safety.
Hatfield denied the outburst, claiming the conversation was calm.
The trial court found for Cornell, issued a DVCPO that protected Cornell, her daughter, Mallow, Mallow’s children who lived in the home, and Cornell’s parents, and Hatfield appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence supported issuance of a DVCPO (manifest weight/sufficiency)	Cornell: Mallow’s eyewitness testimony and petitioner’s fear show Hatfield made violent threats to petitioner and family/household members.	Hatfield: Denies threats; claims conversation was calm and evidence insufficient.	Court upheld DVCPO—trial court’s findings supported by competent, credible evidence; no manifest miscarriage of justice.
Whether trial court erred by admitting Mallow’s prior written statement	Cornell: Statement corroborative and admissible; Mallow corroborated contents and was cross‑examined.	Hatfield: Admission was hearsay and prejudicial.	Admission, if erroneous, was harmless: statement was cumulative, author testified and was cross‑examined, and record shows court did not rely on improper hearsay.

Woolum v. Woolum, 131 Ohio App.3d 818 (12th Dist. 1999) (when issuing a civil protection order courts should consider petitioner’s family or household members).