In re Guardianship of Bond, 2017 Ohio 130

In May 2015 the guardian of Bond’s mother obtained a probate-court protective order against Jonnie Bond; it was served on Bond on June 9, 2015.
Bond did not timely appeal the protective order; she later filed motions to dismiss and for relief from the order in the probate court, which were denied and not appealed.
In August 2015 the guardian moved for contempt, alleging Bond violated the protective order. Bond moved again for relief from the order and to dismiss the contempt motion, arguing the protective order was invalid because the probate court lacked authority to issue a five-year order without a hearing.
The probate court denied Bond’s procedural motions, held a contempt hearing, found Bond in contempt, and fined her $250.00.
Bond appealed the contempt judgment to the Ninth District Court of Appeals, arguing the underlying protective order was improperly issued and therefore could not support a contempt finding.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the contempt finding must be overturned because the probate court improperly issued a five‑year protective order without a hearing	Bond: probate court lacked authority / case law/statute does not allow a five‑year protection order without a hearing	Guardian/State: Bond failed to timely appeal the protective order and subsequent denials of relief; arguments are a collateral attack barred by res judicata	Court: Res judicata bars Bond's collateral attack because she could have raised the challenge on direct appeal; contempt affirmed

State v. Ketterer, 126 Ohio St.3d 448 (2010) (discusses final-judgment effect and preclusive scope relevant to res judicata)