S.P. v. B.M.

Citations

• 2025 Ohio 778

Syllabus

Per Mayle, mother can challenge trial court's subject-matter jurisdiction years after case filed. Texas was child's home state on filing date, so court lacks Uniform Child Custody Jurisdiction and Enforcement Agency (\UCCJEA\) jurisdiction. Absence not temporary under duration test when child was away for six consecutive months ending within six months of filing. Nothing shows that mother stipulated to jurisdictional facts, she could not consent to nonexistent jurisdiction, and record evidence is sufficient to determine home state, so transcripts are unnecessary.