In re G.V.W.

Citations

• 2025 Ohio 5639

Syllabus

Personal jurisdiction; long-arm jurisdiction; R.C. 3111.06(B); R.C. 2307.382; paternity action; Civ.R. 4.3; transacting business in Ohio; waiver of lack-of-jurisdiction defense; Civ.R. 12(H)(1); default hearing; juvenile court, sua sponte, raises defense of lack of personal jurisdiction. The juvenile court did not err when it found it lacked personal jurisdiction over the alleged father in a paternity action because the plaintiff-appellant did not demonstrate the alleged father's acts constituted business transactions as required under R.C. 2307.382(A)(1), Ohio's long-arm jurisdiction statute. The alleged father's failure to enter an appearance in a paternity action did not constitute a waiver of his defense of lack of personal jurisdiction. And where the alleged father did not waive his defense of lack of personal jurisdiction, the juvenile court could raise the defense sua sponte.