Rowell v. Smith

A juvenile court issued temporary visitation orders in a pending case for custody under Ohio Rev. Code 2151.23(A)(2) between a parent and nonparent. When the parent violated the orders, the trial court found the parent in contempt. The court of appeals reversed, concluding that the juvenile court lacked authority to order visitation in a section 2151.23(A)(2) custody case, and thus, the underlying temporary order was invalid, and the parent could not be in contempt of an invalid order. The Supreme Court reversed the judgment of the court of appeals and reinstated the trial court's orders, holding that in exercising its jurisdiction under section 2151.23(A)(2), a juvenile court may issue temporary visitation orders that are in the best interest of the minor child during the litigation. View "Rowell v. Smith" on Justia Law