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Farrens v. Farrens
Ohio Court of Appeals · 2026-06-22
The case concerned Amatha Farrens's appeal from a Fayette County domestic relations court order that terminated her ex-husband Corey's obligation to pay her $20,000 monthly spousal support after finding she was cohabiting with her boyfriend. The Court of Appeals reversed that termination. It held that the trial court's cohabitation finding was not supported by competent, credible evidence because the court improperly relied on the couple's pre-August 2024 conduct and because the post-order record showed only occasional weekend overnight visits while the parties maintained wholly separate residences and finances. The court explained that cohabitation requires both sustained living together and financial interdependence amounting to the functional equivalent of marriage, neither of which was established here.
family law
State v. Ramirez
Ohio Court of Appeals · 2026-06-15
In State v. Ramirez, David Sanchez Ramirez appealed from the Butler County Court of Common Pleas after pleading guilty to five counts of sexual battery for abusing his teenage stepdaughter over three years; the trial court had imposed consecutive sentences totaling 108 months in prison. The Twelfth District Court of Appeals affirmed the sentence. The court held that the trial court properly made the three required findings under R.C. 2929.14(C)(4) at the sentencing hearing and in its entry—namely, that consecutive terms were necessary to protect the public and punish the offender, were not disproportionate to the conduct and danger posed, and that the offenses were part of a course of conduct causing harm so great or unusual that a single term would not reflect its seriousness. The appellate court rejected Ramirez’s arguments that leniency requests, his lack of criminal history, and low recidivism risk undermined those findings, explaining that such factors relate to individual offense sentencing under R.C. 2929.11 and 2929.12 rather than the separate consecutive-sentence analysis.
criminal law
Higle v. Engle
Ohio Court of Appeals · 2026-06-08
In Higle v. Engle, Ralph Curtis Engle II appealed the Brown County Court of Common Pleas' denial of his Civ.R. 60(B) motion, which sought relief from an August 5, 2024 ex parte domestic violence civil protection order (DVCPO) issued against him on behalf of Abigail Higle and their child following Higle's petition. The Twelfth District Court of Appeals dismissed the appeal for lack of jurisdiction. The court explained that the ex parte order was not final or appealable under R.C. 3113.31(G)(1) and had been superseded by the parties' October 17, 2024 consent agreement, which was a final appealable order that Engle never directly appealed. It further held that a Civ.R. 60(B) motion cannot be used as a substitute for a timely appeal or to obtain review of issues that should have been raised in a direct appeal from the consent agreement.
family lawprocedure
In re L.M.H.
Ohio Court of Appeals · 2026-06-01
The case involved a father's appeal from the denial of his Civ.R. 60(B) motion seeking to vacate a child-support order entered after his adopted daughter was adjudicated dependent and placed in agency temporary custody. The juvenile court had ordered the father to pay support after imputing income to him, and he later argued that the order was improper because the court failed to consider the discretionary factors in R.C. 2151.361(B) applicable to adoptive parents. The Twelfth District Court of Appeals affirmed the denial, holding that res judicata barred the father from raising the argument for the first time in a 60(B) motion rather than in his earlier objections or on direct appeal from the support order. The court further reasoned that any error in applying the statute rendered the order voidable rather than void, so it could not be collaterally attacked months later, and that the father's related ineffective-assistance claims were likewise procedurally foreclosed in this civil proceeding.
family lawprocedure
Leyes v. Leyes
Ohio Court of Appeals · 2026-06-01
In Leyes v. Leyes, Gary Leyes appealed a Clinton County divorce decree requiring him to pay his former wife spousal support after a nearly 18-year marriage with no children. The trial court awarded Sheila Leyes (now Elkins) an $18,000 lump-sum payment plus $2,400 monthly for 120 months, terminable on cohabitation, remarriage, or death, after the magistrate had recommended indefinite support. The Court of Appeals affirmed, holding that the trial court properly exercised its discretion under R.C. 3105.18(C)(1) by balancing the parties' incomes (including Husband's regular overtime), earning abilities, ages, health conditions, marital lifestyle, and assets, while noting that Wife's multiple serious medical issues left her unable to work or support herself. The court rejected challenges to the lump-sum award (waived for lack of specific objection), inclusion of overtime in income calculations, assumed tax rate, and lack of medical expert testimony, finding the trial court's determinations supported by the evidence and not an abuse of discretion.
family law
State v. Lane
Ohio Court of Appeals · 2026-06-01
In State v. Lane, the defendant appealed her convictions for grand theft of a motor vehicle and attempted grand theft of a firearm, arguing that the offenses should have merged as allied offenses of similar import under R.C. 2941.25 because both arose from the same February 2025 incident in which she and an accomplice stole a car containing a gun in the glove box. The trial court had rejected merger at sentencing and imposed consecutive prison terms, and the Twelfth District Court of Appeals affirmed. The court held that the offenses were of dissimilar import under the Ruff test because Lane’s conduct caused separate and identifiable harms: she not only took the vehicle but also separately removed the firearm, transported it to her own bedroom, and retained it there apart from the car, as shown by the gun’s location four days later alongside other stolen items. This course of conduct, the court explained, went beyond cases where multiple items are taken together in a single theft episode and remain together without further separate possession. The court therefore concluded that the trial court properly refused to merge the convictions.
criminal lawprocedure