In re Z.S., 2011 Ohio 3269

Appellant Nathaniel Simpson appeals a juvenile court order that adopted a magistrate’s decision to dismiss his amended complaint without prejudice.
Simpson sought relief under R.C. 3119.961 to vacate a prior paternity acknowledgment based on anticipated child support actions by the agency.
The initial magistrate dismissed Simpson’s complaint for failure to satisfy the six-month genetic-test window under R.C. 3119.962(A)(1)(a).
Simpson filed an amended complaint and motions, but did not file objections to the magistrate’s initial decision; the court later adopted the magistrate’s ruling.
After hearings and responses, the magistrate concluded the genetic-test timing did not satisfy statutory requirements and the court lacked authority to compel testing under state law.
The juvenile court ultimately dismissed Simpson’s amended complaint without prejudice, and Simpson appealed, challenging the court’s discretion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the appeal is from a final, reviewable order	Simpson argues the court’s order is final and subject to review.	Agency contends the order is not final because objections were not explicitly ruled on and it is thus non-final.	Appeal dismissed for lack of finality.

Hall v. Cleveland State Univ., 129 Ohio App.3d 767 (Ohio 1998) (non-merits dismissal without prejudice not final; refiling permitted)