In re K.B., 2018 Ohio 3600

Cedric Douglas (pro se) filed motions in juvenile court seeking non-parent visitation and later custody of K.B.; he is not K.B.’s biological father but claims a parental role since birth.
After initial hearings in 2016, a magistrate denied interim visitation; Douglas withdrew a prior custody motion and unsuccessfully objected to the magistrate’s conduct.
Douglas filed renewed motions for visitation, interim parenting time, appointment of a CASA, and custody in late 2017–early 2018; hearings occurred before the magistrate (March 30, 2018).
The magistrate denied visitation, interim parenting time, and custody on April 16, 2018, finding these were not in the child’s best interest; Douglas timely objected and requested a transcript.
The trial court overruled Douglas’s objections and adopted the magistrate’s decision before a transcript was filed or Douglas could supplement objections.
Douglas appealed, arguing bias/disqualification and that he met R.C. 3109.051 standards for non-parent visitation; the appellate court reversed and remanded.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether judicial bias/disqualification required reversal	Douglas argued magistrate and trial judge were biased and decisions resulted from prejudice	Court/defendants relied on statutory disqualification procedure and record showing no bias	No bias shown; disqualification procedure is exclusive and prior rulings do not by themselves disqualify (assignment overruled)
Whether trial court erred by adopting magistrate's decision without transcript/supplemental objections	Douglas argued he timely objected and requested transcript, and should have chance to file transcript and supplement objections to support factual claims for visitation/custody	Trial court treated objections as unrelated/insufficient and adopted magistrate before transcript was filed	Reversed: trial court abused discretion by ruling before allowing time to file transcript and supplement objections; remand for further proceedings

In re Disqualification of Capper, 134 Ohio St.3d 1271 (2012) (disqualification of a judge is extraordinary and governed by R.C. 2701.03)
Jones v. Billingham, 105 Ohio App.3d 8 (1995) (R.C. 2701.03 procedure is the exclusive means to claim common pleas judge bias)
State v. Osie, 140 Ohio St.3d 131 (2014) (court of appeals cannot rule on trial judge disqualification outside R.C. 2701.03)
In re Disqualification of George, 100 Ohio St.3d 1241 (2003) (judge presumed unbiased; appearance of bias must be compelling)
In re Disqualification of Aubry, 117 Ohio St.3d 1245 (2006) (prior proceedings over same parties do not automatically disqualify a judge)
Blakemore v. Blakemore, 5 Ohio St.3d 217 (1983) (standard for abuse of discretion)