Migliara v. Migliara

Citations

• 2022 Ohio 2111

Syllabus

DIVORCE – INTERPRETER – WAIVER – COUNSEL: In a divorce case, the magistrate did not err by not appointing an interpreter for defendant wife's psychological interviews because she was not entitled to an interpreter under the United States Constitution, the Ohio Revised Code, or the Ohio Rules of Superintendence, and the record demonstrates that she and the interviewers were able to communicate effectively. Where wife failed to object to the admission of the custody-evaluation report at trial or raise the issue in her objections to the magistrate's decision, she waived the right to argue against the report's admission on appeal. The magistrate did not violate wife's rights to counsel or due process by asking wife directly if she was willing to undergo a psychological evaluation. The magistrate did not commit plain error by permitting wife's trial counsel to withdraw because counsel demonstrated that her representation of wife had been rendered unreasonably difficult by wife's conduct.