McGhee v. McGhee

Summary

The Ohio Second District Court of Appeals affirmed a trial court judgment adopting a magistrate’s decision concerning child custody, parenting time, and related motions. The court held that the pro se appellant’s failure to comply with Ohio Appellate Rule 16 prevented meaningful appellate review and warranted affirmance.

Holdings

1. An appellant's failure to comply with the mandatory requirements of Ohio App.R. 16, particularly the failure to present a coherent and understandable argument explaining how the trial court erred, prevents meaningful appellate review and supports affirmance of the judgment.
2. Although courts may afford pro se litigants some flexibility, pro se litigants are held to the same rules and procedures as litigants represented by counsel.

Questions Presented

1. Whether the appeal could be resolved when Mother's pro se brief failed to comply with Ohio App.R. 16 and did not present a coherent argument identifying error in the trial court's adoption of the magistrate's decision.

Disposition

affirmed