Walsh v. Walsh, 2020 Ohio 6998

Kenneth J. Walsh (pro se) appealed an October 20, 2020 magistrate’s amended order requiring him to pay $2,000/month spousal support, enforcing a November 17, 2016 dissolution judgment entry, while his June 12, 2020 "Post Judgment Motion to Reopen" remained pending.
Carmella A. Walsh (through counsel) moved to dismiss the appeal as interlocutory.
The court framed the threshold jurisdictional question: whether the magistrate’s order is a "final order" subject to immediate appellate review under Ohio law.
The court applied Article IV, Section 3(B)(2) of the Ohio Constitution and R.C. 2505.02(B) regarding final appealable orders.
The court noted magistrates may enter effective orders without judicial approval for procedural matters, but a magistrate’s order that disposes of a claim requires judicial approval to be appealable.
Conclusion: the October 20, 2020 magistrate’s order was not a final, judicially approved order and thus was interlocutory; the appellate court dismissed the appeal for lack of jurisdiction.

Issue	Walsh's Argument	Carmella's Argument	Held
Whether the Oct. 20, 2020 magistrate order is a final appealable order	Walsh treated the magistrate’s order as immediately appealable and challenged the spousal-support directive	The order is interlocutory because it lacks judicial approval and does not dispose of all claims	The order is not a final appealable order; appeal dismissed for lack of jurisdiction

Noble v. Colwell, 44 Ohio St.3d 92 (recognizing appellate review is limited to final orders)
Gen. Acc. Ins. Co. v. Ins. Co. of N. Am., 44 Ohio St.3d 17 (when an order is not final an appellate court lacks jurisdiction and must dismiss the appeal)