H.C. v. J.C., 2020 Ohio 1227

Plaintiff H.C. filed a petition for a civil stalking protection order (CSPO) on Jan. 4, 2019 against her ex–daughter‑in‑law, J.C., after J.C. allegedly harassed H.C. and H.C.'s boyfriend (social‑media posts, threats to tell H.C.'s children, and an aggressive street approach toward H.C.'s sister).
A full hearing before a magistrate was held on April 12, 2019.
On May 8, 2019 the magistrate issued a 30‑month CSPO; the trial court adopted the magistrate's decision the same day and entered findings of fact and conclusions of law.
J.C. did not file written objections to the magistrate’s decision under Civ.R. 65.1(F)(3)(d)(i) within 14 days before filing her appeal.
The primary procedural question on appeal was whether failure to file timely objections under Civ.R. 65.1(G) deprived the appellate court of jurisdiction to consider the merits.
The Fifth District dismissed the appeal without reaching the merits, holding that Civ.R. 65.1(G) requires timely objections prior to filing an appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the CSPO was properly granted (merits)	H.C.: J.C.'s social‑media posts, threats, and confrontations constituted stalking supporting a CSPO	J.C.: Trial court erred; findings inconsistent with testimony and evidence	Appeal dismissed for lack of jurisdiction due to failure to file timely objections under Civ.R. 65.1(G); merits not reached
Whether the trial court's factual findings were inconsistent with the evidence	H.C.: Magistrate's findings were supported by testimony and evidence presented at the hearing	J.C.: Findings of fact contradicted hearing testimony and evidence	Same — procedural default (no timely Civ.R. 65.1 objections) bars appellate review; court declined to address factual disputes

The opinion relies principally on Civ.R. 65.1 and a line of Ohio appellate decisions applying Civ.R. 65.1(G) to require timely objections before appeal. No officially reported (volume and reporter) cases are cited in the opinion.