Galluzzo v. Galluzzo, 2013 Ohio 3647

Galluzzo failed to pay court costs in a domestic relations matter; contempt proceedings led to a 40-hour community service order to “work off” costs.
Trial court journal entry (July 20, 2012) showed an outstanding balance of $986.97 and scheduled a show-cause hearing for October 5, 2012.
Galluzzo, indigent with Social Security income, argued his finances left him with little to pay costs; he sought continuance and later dismissal of the hearing.
During the hearing, the court offered community service as a substitute for payment, asserting authority to convert costs to labor for six months.
Galluzzo argued such an order violated constitutional protections against imprisonment for civil debt; the defense relied on case law distinguishing fines from civil costs.
The appellate court reversed and vacated the trial court’s judgment, holding that ordering community service to pay civil court costs was improper.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether ordering community service to pay court costs is lawful	Galluzzo argues costs are civil debt and cannot be paid via community service.	Galluzzo contends the court acted within its contempt powers to enforce payments.	Not lawful; order to work off costs reversed.

Strattman v. Studt, 20 Ohio St.2d 95 (1969) (imprisonment for civil debt prohibited; distinction between fines and costs)
Glasscock, 91 Ohio App.3d 520 (1993) (civil debt; cannot compel community service to pay costs)
Strongsville v. Waiwood, 62 Ohio App.3d 521 (1989) (trial courts may collect costs like civil judgments)
In re Buffington, 89 Ohio App.3d 814 (1939) (contempt cannot collect civil judgments for costs)