Abdelaziz v. Lugo

Summary

The Ohio Fifth District Court of Appeals affirmed the Delaware County Domestic Relations Division’s denial of Rana Abdelaziz’s objections to a parenting coordinator’s decision. The court held that the parenting coordinator acted within the authority granted by the parties’ agreed appointment order and that the trial court properly required an affidavit supporting objections and could deny them without an oral hearing. The court rejected all four assignments of error, including the appellant’s due process challenges.

Holdings

1. The parenting coordinator acted within the authority granted by the parties' agreed order and addendum because those documents expressly authorized decisions implementing Lugo's parenting time incrementally and addressing vacation parenting time.
2. The trial court did not violate due process by denying the objections without an oral hearing because it provided notice of the objection procedure, and the appellant failed to comply with the required affidavit filing.
3. The trial court did not violate due process by failing to establish an objection process because Delaware County Local Rule 33 provided such a process and the court's November 26, 2024 judgment entry separately specified the filing requirements.
4. Requiring an affidavit with objections did not impermissibly limit legal objections or violate due process.

Questions Presented

1. Whether the parenting coordinator exceeded the authority granted by the parties' agreed parenting coordinator order by eliminating supervision and expanding or modifying Lugo's parenting time.
2. Whether the trial court violated due process by ruling on Abdelaziz's objections without conducting an oral hearing.
3. Whether the trial court violated due process by failing to establish an objection process in its local rules or parenting coordinator order.
4. Whether requiring an affidavit with objections improperly limited legal objections and violated due process.

Disposition

affirmed