Combs v. Sherwin-Williams Co.

Citations

• 2026 Ohio 562

Syllabus

Motion to show cause; civil contempt; abuse of discretion; agreed order; consent order; due process; pro se. Judgment affirmed. The trial court did not abuse its discretion when it found appellant in contempt of court. Appellant did not present any testimony or evidence that his attorney was not authorized to enter into an interim agreement with appellee at a status conference; challenge the allegation that he failed to comply with the terms of the resulting agreed order; or otherwise rebut appellee's initial showing of contempt. Nor were appellant's due-process rights violated based on the record. Appellant — who was initially represented by counsel but elected to proceed pro se — had notice of appellee's motion to show cause; a reasonable opportunity to defend against or explain the allegations raised therein, both in writing and at the show-cause hearing; and the opportunity to testify and to call other witnesses in his defense or to offer an explanation for his failure to comply with the agreed order.