· 2/9/2026

Robertson v. Park

Citations

  • 2026 Ohio 388

Syllabus

Grandmother appeals order granting domestic violence civil protection order (DVCPO) prohibiting contact with granddaughter. Granddaughter experienced suicidal thoughts under grandmother's care. Civ.R. 65.1, not Civ.R. 53 applies in DVCPO hearings and does not require specificity in objections. Social worker who conducted psychosocial assessment on granddaughter could offer opinion as to the cause of the granddaughter's mental health issues. Civ.R 65.1 governs discovery in DVCPO proceedings and does not require exchange of expert reports prior to the full hearing. Grant of DVCPO supported by evidence that Grandmother caused granddaughter to suffer mental injury rendering her an \abused child\ under the DVCPO statute.

Judges: Byrne

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