Edwards v. Horton, 2022 Ohio 3989

CSEA registered an administrative child-support order with the Hamilton County Juvenile Court in Aug. 2021 based on an earlier administrative paternity determination supported by genetic testing.
The juvenile court adopted the registered administrative support order the following day.
Horton filed an "Objection to Administrative Order of Support," disputing the genetic-testing result and attaching the administrative paternity order and testing results.
Horton then filed a "Notice of Special Appearance" and an affidavit denying paternity while asserting sovereign-citizen style claims ("cestui que trust," "paramount security interest holder").
A magistrate heard Horton’s objection, found he offered no basis to invalidate the administrative order, and denied relief. The juvenile court later overruled Horton’s objection, finding it had personal jurisdiction over him. Horton appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the juvenile court lacked personal jurisdiction over Horton.	Court had jurisdiction via registered administrative order; Horton’s filings did not preserve a jurisdictional defense.	Horton: he never voluntarily submitted to jurisdiction; his later "special appearance" preserved lack-of-jurisdiction defense; asserted trust/sovereign-citizen theory.	Horton waived any personal-jurisdiction objection by failing to raise it in his first appearance; court properly exercised jurisdiction.
Whether Horton was properly served with the administrative order.	Service not disputed below; any service defect was not preserved.	Horton (first raised on appeal): he was not properly served with the administrative order.	Argument waived for failure to raise in the trial court; cannot be asserted for the first time on appeal.

State ex rel. Zollner v. Indus. Comm., 66 Ohio St.3d 276, 611 N.E.2d 830 (1993) (a party who fails to raise an argument below waives it on appeal).