Givens v. Hanson

Citations

• 2024 Ohio 416

Syllabus

CIVIL – Trial court's failure to consolidate cases does not constitute an abuse of discretion where no motion to consolidate is filed and there is no evidence in the record demonstrating consolidation was warranted pursuant to Civ.R 42. A reviewing court must presume the validity of the lower court proceedings where no transcript of the proceedings in made a part of the record, and the appellant does not avail herself of the alternatives in App.R. 9(C) and (D).