A.H. v. T.H.

Citations

• 2023 Ohio 1969

Syllabus

Domestic violence civil protection order R.C. 3113.31 frivolous conduct R.C. 2323.51 abuse of discretion plain error attorney fees. The trial court did not err in awarding attorney fees against a petitioner in a domestic violence civil protection order proceeding where it found the petitioner had engaged in frivolous conduct pursuant to R.C. 2323.51. The trial court did not err in finding that petitioner-appellant had engaged in frivolous conduct pursuant to R.C. 2323.51. Specifically, the trial court did not err in considering the petitioner-appellant's attempt to voluntarily dismiss her action minutes before a full hearing on her petition and did not improperly rely on evidence outside of the record. The trial court's award of attorney fees did not constitute plain error.