In Re A.G., 139 Ohio St. 3d 572

A.G. was the child subject to custody litigation arising from a divorce between Lolita and Patrick, with prior custody disputes and abduction episodes involving Patrick.
The Henry County domestic-relations court certified the custody matter to the Ottawa County Juvenile Court under R.C. 3109.04(D)(2) due to risk of harm to A.G.
The Ottawa County Juvenile Court appointed a Guardian Ad Litem and, later, considered best-interest factors and psychological evaluations for A.G.
A.G., though not a party to the divorce action, sought attendance at hearings, including a motion to modify visitation; the GAL and trial court sought to protect her interests via in-camera interviews and representation by counsel.
The juvenile court conducted in-camera interviews, limited attendance, and ultimately denied A.G.’s attendance at the November 2010 hearing on Patrick’s motion, while allowing other forms of input through counsel and the GAL.
The Sixth District affirmed the trial court’s exclusion of A.G. from the hearing; the Supreme Court of Ohio granted discretionary review to address whether a child may be excluded from custody proceedings ancillary to a divorce.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a child is a proper party in a divorce ancillary custody action.	A.G. has an interest in the dispute and should participate.	A.G. is not a proper party; only parents may invoke modification; motions by a child lack independent legal significance.	A child is not a proper party; the court may hear the child through other mechanisms.
Whether due process requires the child’s attendance at custody proceedings.	Due process and open courts require attendance where there is a direct interest.	Attendance is not required; the child can be heard via in-camera interview, GAL, and counsel.	Due process does not mandate attendance; exclusion may be appropriate when in the child’s best interest considering total circumstances.
What is the correct scope of jurisdiction when a case is certified to juvenile court from a domestic-relations court?	Certification preserves the child’s and parents’ rights and opportunities to be heard in juvenile court.	Certification does not alter the domestic-relations court’s subject-matter jurisdiction over the divorce/custody issues.	Certification keeps matters governed by the relevant statutes (R.C. 3109.04) with the juvenile court exercising jurisdiction where appropriate.

In re Whitaker, 36 Ohio St.3d 213 (1988) (upheld in-camera child interview to protect the child's interests)
In re Poling, 64 Ohio St.3d 211 (1992) (child custody decisions harmonized with prior decree under 3109.04)
Hanna v. Hanna, 177 Ohio App.3d 233 (2008) (limits on who may invoke modifications; procedural posture matters)
Loetz v. Loetz, 63 Ohio St.2d 1 (1980) (continuing and exclusive jurisdiction upon certification)
Handelsman v. Handelsman, 108 Ohio App.3d 30 (1958) (recognizes limited statutory authority over custody matters and GAL role)