In re J.F.
2017 Ohio 1492
| Ohio Ct. App. | 2017Background
- Mother and Father are unmarried parents of an eight-year-old daughter; they had an informal custody/support arrangement after the child's birth.
- Father filed for custody in 2014 but dismissed; Mother requested a formal support order from Butler CSEA.
- CSEA issued an administrative order (effective May 27, 2015) requiring Father to pay child support; both parties challenged it and a magistrate hearing occurred December 22, 2015.
- Magistrate initially set support effective 05/27/2015 and denied Mother's requests for retroactive support to the child’s birth and reimbursement of birth/medical/daycare expenses; Mother objected only to the dental-insurance calculation.
- Juvenile court sustained the dental-insurance objection, remanded for recalculation, and later adopted a recalculated support order; Mother appealed, raising three errors about effective date and retroactive reimbursement.
- Court of Appeals held Mother waived her appellate claims by failing to file specific objections below and failed to provide transcripts, so the judgment was affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether child-support effective date should be the child’s date of birth | Mother: support should run from birth; she presented records and testimony of unpaid expenses | Father: order effective date should remain the administrative order date; no timely objection below | Court: Waived — Mother failed to object below, so cannot raise this on appeal |
| Whether Father must reimburse uncovered medical/birth expenses retroactively | Mother: Father should pay prior birth/medical expenses incurred for child | Father: Mother failed to timely pursue/support or object, so not entitled to retroactive reimbursement | Court: Waived — no specific objection below; appeal barred |
| Whether Mother is entitled to reimbursement for birthing expenses | Mother: seeks reasonable and necessary birthing expenses | Father: same procedural defense — failure to preserve issue | Court: Waived — issue not preserved and no plain-error claim |
| Whether appellate review is possible without trial transcripts | Mother: did not supply transcripts or acceptable alternative | Father: reliance on record as presented; presumption of regularity | Court: Because transcripts absent, presumes regularity and affirms judgment |
Key Cases Cited
- In re K.P.R., 197 Ohio App.3d 193 (12th Dist. 2011) (failure to raise specific objections at trial waives claims on appeal)