In re Guardianshp of Bakhtiar, 2021 Ohio 2162

Fourough Bakhtiar was adjudicated incompetent; long-running guardianship litigation followed.
Spike & Meckler Law Firm had represented Bakhtiar’s daughter, Jaleh Presutto, since 2013; Presutto had at times been guardian and caregiver.
On May 16, 2016, Zachary Simonoff was appointed guardian of Bakhtiar’s person and estate.
In January 2019 the Law Firm moved for attorney fees for work May 14, 2016–Dec 31, 2018, attaching detailed billing; the guardian and the ward’s attorney consented to necessity and benefit.
No party (including appellant Khashayar Saghafi, Bakhtiar’s son) objected in the probate court; the probate court awarded $100,521.52 on May 16, 2019.
Saghafi appealed, arguing insufficiency of evidence for the fee award and that the probate court failed to make required findings; the appellate court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the probate court abused its discretion in awarding $100,521.52 in attorney fees	Saghafi: fees were incurred while Presutto had been removed as guardian for criminal misconduct; no evidence fees were necessary or benefitted the ward	Law Firm/guardian: services were necessary and beneficial; ward’s counsel and guardian consented; no objections below	Affirmed — Saghafi waived challenge by not objecting in trial court; cannot raise sufficiency on appeal
Whether the court’s failure to make explicit findings required reversal	Saghafi: probate entry lacked required findings as to necessity/benefit	Law Firm/guardian: any omission is harmless where no party preserved a challenge to the award’s merits	Any omission was harmless; judgment affirmed

LeFort v. Century 21-Maitland Realty Co., 32 Ohio St.3d 121 (1987) (failure to object in the trial court waives appellate challenge)