State ex rel. Moir v. Kovack (Slip Opinion), 47 N.E.3d 831

Relator Gabriella Moir is a plaintiff in a Medina County domestic-relations divorce (Denkewalter). Judge Mary R. Kovack (the only Medina judge) recused herself because a party is an attorney who practices in her court; the Chief Justice assigned Judge Carol J. Dezso (Summit County) to the case.
After recusal, Kovack (acting as the court’s administrative judge) issued orders assigning Summit County magistrates (Deborah Matz and Stephan Collins) to hear motions in the case; those magistrates issued rulings.
Moir challenged those assignments, arguing only the assigned visiting judge (Dezso) may preside or refer matters; she filed this original-action petition for a writ of prohibition seeking to bar anyone other than Dezso from hearing or referring matters in the case.
The Ninth District considered related arguments on appeal and treated errors in magistrate assignment as voidable (not void); Moir also has appellate remedies available.
The Supreme Court of Ohio held Kovack’s recusal removed her jurisdiction to act in the case (including administrative assignments) and issued a peremptory writ against Kovack only; the court denied relief as to Dezso, who retains authority to appoint magistrates under Civ.R. 53(A).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does Kovack have authority to assign magistrates after recusal?	Kovack lacked authority after recusal; only the assigned judge may act.	Kovack, as administrative judge, may issue ministerial/administrative orders including assignments.	Kovack patently and unambiguously lacked jurisdiction to act; writ granted against Kovack.
May the assigned visiting judge (Dezso) appoint magistrates?	Moir sought to bar Dezso from referring matters to others, insisting only Dezso act.	Dezso may assign magistrates under Civ.R. 53(A) to assist in adjudication.	Dezso may appoint magistrates; no writ issued against Dezso.
Is an appeal an adequate remedy (so prohibition is inappropriate)?	Moir argued prohibition necessary to prevent future improper assignments.	Respondents argued Moir had an adequate remedy by appeal; Ninth District review was available.	Because an adequate appellate remedy existed, Moir must show lack of jurisdiction is patent and unambiguous; she did so as to Kovack but not Dezso.
Are actions of improperly assigned magistrates void or voidable?	Moir contended those actions were void.	Respondents and Ninth District treated such errors as voidable and subject to forfeiture if not timely objected.	The court did not decide merits of past actions here; noted Ninth District held such actions voidable.

State ex rel. Bell v. Pfeiffer, 131 Ohio St.3d 114 (2012) (standards for extraordinary-writ relief)
State ex rel. Miller v. Warren Cty. Bd. of Elections, 130 Ohio St.3d 24 (2011) (writ-of-prohibition requisites)
Chesapeake Exploration, L.L.C. v. Oil & Gas Comm., 135 Ohio St.3d 204 (2013) (patent-and-unambiguous lack of jurisdiction excusing other remedies)
State ex rel. Johnson v. Jensen, 140 Ohio St.3d 65 (2014) (dismissing improperly named respondents when no authority or intent to act)