Marinakis v. Marinakis

Citations

• 2025 Ohio 2554

Syllabus

A probate court does not abuse its discretion solely by ordering payment of guardian ad litem fees without first satisfying the procedural requirements of a local rule related to fee payment where enforcement of the local rule is discretionary and there is no resulting prejudice. In ordering payment of guardian ad litem fees, a probate court need not always distinguish between traditional guardian ad litem services and legal services rendered by an attorney-guardian ad litem even in the absence of an express dual appointment as these roles may necessarily overlap. A probate court's decision to authorize contemporary payment of guardian ad litem fees falls well within its broad discretion to manage estate administration.