In re W.W., 2013 Ohio 827

CSEA appeals a juvenile court dismissal of its motion to establish child support for W.W., who had turned 18 before the matter was considered.
W.W. was born October 26, 1993; CCDCFS initially filed neglect, leading to temporary custody and later legal custody with W.W.'s paternal grandparents G.K. and B.K.
CSEA filed the support motion on October 30, 2007; service initially by certified mail to C.C. and B.K. failed, so ordinary mail service followed.
The magistrate denied the motion on May 18, 2012, due to W.W. reaching the age of majority; CSEA sought relief, which the court denied.
On August 7, 2012, the juvenile court granted an order adopting the magistrate’s May 17, 2012 decision, prompting the appeal on lack of jurisdiction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the juvenile court have subject matter jurisdiction to order support for a child who reached majority?	CSEA argues court retained jurisdiction.	W.W. no longer a child; court lacked jurisdiction.	No jurisdiction once child reached 18; order affirmed.
Is a third-party motion for retroactive child support properly actionable without a parentage action?	CSEA seeks retroactive support despite no parentage action.	Carnes not controlling; different posture.	Not applicable; court properly dismissed for lack of jurisdiction.

Cleveland v. Abrams, 8th Dist. Nos. 92843 and 92844, 2010-Ohio-662 (Ohio 2010) (subject-matter jurisdiction; de novo review standard applied by appellate court)
Elzey v. Springer, 2004-Ohio-1373 (12th Dist. 2004) (statutory framework for juvenile court jurisdiction over support matters)
McIntyre v. McIntyre, 2005-Ohio-7083 (7th Dist. 2005) (age of majority affecting child-status and support duties)
Maphet v. Heiselman, 13 Ohio App.3d 278, 469 N.E.2d 92 (12th Dist. 1984) (older cases on continuing support after majority; distinguish retroactive claims)
Carnes v. Kemp, 104 Ohio St.3d 629, 821 N.E.2d 180 (2004-Ohio-7107) (retroactive support; parentage action relevance)