In re P.A.

Citations

• 2026 Ohio 660

Syllabus

On petitioner's appeal of juvenile court's dismissal of his uncontested petition for custody over his minor half-brother. The trial court erred by failing to comply with rules of court regarding magistrate decisions without cause to do so or proper notice to petitioner. Trial court's explanation that the magistrate's decision was incomplete and missing information it deemed to be crucial was not justified, where the trial court wholly failed to identify what that information was, failed to notify counsel that any such information was required, and failed to respond to counsel's inquiries about the status of the case. Trial court's decision to informally reserve magistrate's decision for nearly six months without notifying counsel, and without approving or rejecting the decision on the record was prejudicial to the petitioner and the juvenile. Trial court's terse explanation that it was \overburdened\ and had a \congested docket\ is not a sufficient reason for the lengthy delay where the case was uncontested, the facts were undisputed, and the legal relief sought was uncomplicated. Judgment reversed and cause remanded with instructions