Henderson v. Cuyahoga Cty. Div. of Children & Family Servs.

[Cite as Henderson v. Cuyahoga Cty. Div. of Children & Family Servs., 2026-Ohio-3960.] COURT OF APPEALS OF OHIO EIGHTH APPELLATE DISTRICT COUNTY OF CUYAHOGA SHONTE HENDERSON, : Plaintiff-Appellant, : No. 115997 v. : CUYAHOGA COUNTY DIVISION OF CHILDREN AND FAMILY SERVICES, : Defendant-Appellee. : JOURNAL ENTRY AND OPINION JUDGMENT: AFFIRMED RELEASED AND JOURNALIZED: October 8, 2026 Administrative Appeal from the Cuyahoga County Court of Common Pleas Case No. CV-25-121629 Appearances: Shonte Henderson, pro se. Michael C. O’Malley, Cuyahoga County Prosecuting Attorney, and Leslie J. Shafer, Assistant Prosecuting Attorney, for appellee. ON RECONSIDERATION ANITA LASTER MAYS, J.: {¶ 1} Pursuant to App.R. 26(A)(1), plaintiff-appellant Shonte Henderson (“Henderson”) has filed an application for reconsideration of this court’s opinion in Henderson v. Cuyahoga Cty. Div. of Children & Family Servs., 2026-Ohio- 2829 (8th Dist.), which we issued on July 23, 2026.1 {¶ 2} The test regarding whether to grant a motion for reconsideration under App.R. 26(A)(1)(a) “‘is whether the motion . . . calls to the attention of the court an obvious error in its decision or raises an issue for our consideration that was either not considered at all or was not fully considered by [the court] when it should have been.’” State v. Dunbar, 2007-Ohio-3261, ¶ 182 (8th Dist.), quoting Matthews v. Matthews, 5 Ohio App.3d 140, 143 (10th Dist. 1982). The motion filed herein calls to the attention of this court an issue that was either not considered at all or was not fully considered by the court when it should have been. Accordingly, we grant the motion for reconsideration, vacate the earlier opinion, and issue this opinion in its place. See App.R. 22(C); see also S.Ct.Prac.R. 7.01. {¶ 3} Henderson appeals the judgment of the Cuyahoga County Court of Common Pleas dismissing, for lack of subject-matter jurisdiction, her R.C. 2506.01 administrative appeal from a July 8, 2025 letter issued by defendant-appellee 1The original decision in this appeal, Henderson v. Cuyahoga Cty. Div. of Children & Family Servs., 2026-Ohio-2829 (8th Dist.), released on July 23, 2026, is hereby vacated. This opinion, issued upon reconsideration, is the court’s journalized decision in this appeal. See App.R. 22(C); see also S.Ct.Prac.R. 7.01. Cuyahoga County Division of Children and Family Services (“CCDCFS”). The trial court granted CCDCFS’s motion to dismiss pursuant to Civ.R. 12(B)(1) in a journal entry filed December 15, 2025, and assessed costs to Henderson. Henderson appeared pro se in the trial court and appears pro se in this court. {¶ 4} Following the release of this court’s prior opinion, Henderson filed an application for reconsideration pursuant to App.R. 26(A) on July 25, 2026, in which she directs this court’s attention to the Notice to Correct the Record that CCDCFS filed on June 5, 2026, before the prior opinion was released. In that notice, CCDCFS advised this court that the dispositions listed in the July 8, 2025 letter affirmed both indicated and substantiated dispositions, correcting the inaccurate statements in its appellate brief. Because the prior opinion rested in part on the premise that the July 8, 2025 letter upheld an indicated disposition alone, the application for reconsideration is granted, the prior opinion and judgment are vacated, and this opinion is substituted in its place. {¶ 5} After a thorough review of the record and the applicable law, we affirm the judgment of the trial court. I. Facts and Procedural History {¶ 6} CCDCFS is the public children services agency for Cuyahoga County. It is required to investigate reports of child abuse and neglect occurring within the county. R.C. 2151.421; R.C. 5153.16. Upon completing an investigation, the agency must issue a disposition on the report. R.C. 2151.421(I)(5). The disposition is limited to one of the categories set out in Ohio Adm.Code 5180:2-1-01, among them “substantiated,” “indicated,” and “unsubstantiated.” Case information generated through these investigations is recorded in the Statewide Automated Child Welfare Information System (“SACWIS”). {¶ 7} An alleged perpetrator who receives a disposition finding may appeal that finding to the agency, which then conducts an administrative review. Ohio Adm.Code 5180:2-33-20. Following the review, the agency is to change the disposition if it was made in error, if the alleged perpetrator did not engage in conduct constituting child abuse or neglect, or if the disposition is not supported by the totality of the information presented. Ohio Adm.Code 5180:2-33-20(G). “The decision of the [agency] regarding the report disposition appeal shall be final and the decisions are not subject to state hearing review under [R.C. 5101.35].” Ohio Adm.Code 5180:2-33-20(H). {¶ 8} According to her appellate brief, Henderson is a registered nurse and a resident of Cuyahoga County who, in 2024, began pursuing the licensing process to own and operate a residential facility serving youth, and who learned during that process that administrative dispositions recorded in SACWIS could prevent her from obtaining licensure. She states that she then requested an appeal of the dispositions through the agency, that before the appeal meeting, she requested documentation and evidence supporting the allegations and did not receive the materials she asked for, and that she was not informed of the specific allegations to be addressed. She further states that during the meeting she was not permitted to cross-examine witnesses, review investigative materials, or challenge the evidence relied upon by the agency. Henderson also asserts that her SACWIS record contains three substantiated findings, from 2001, 2008, and 2015. {¶ 9} The July 8, 2025 letter that was issued to Henderson was signed by Chris Snider (“Snider”), Senior Manager, on agency letterhead bearing the address 3955 Euclid Avenue, Cleveland, Ohio 44115. The letter stated that, “[a]fter gathering information from the case record and considering the information you shared at the Administrative Appeal held on April 1, 2025, it has been determined that the disposition of Neglect Indicated on the appealed intake (#23116300) will be” upheld, and that “[t]he dispositions for Intakes 3837600, 3810995, and 3760179 will remain unchanged due to the absence of documentation or evidence to support a change in the dispositions.” The stated reason, marked on the form, was that “[t]he appellant did engage in neglect as defined in the Ohio Revised Code.” The letter also altered two other intakes, directing that Intake No. 4486958 be altered to unsubstantiated and that Intake No. 10847589 be altered for lack of evidence of neglect, and set out the agency’s explanation for each of those changes. The letter did not identify which disposition category attached to each of the three intakes were left unchanged. It closed by advising that the appeal decision is final and not subject to state hearing review under R.C. 5101.35, that the principals of the report would be notified in writing of any changes to dispositions, and that SACWIS would be updated to reflect any revisions. {¶ 10} Henderson filed a notice of appeal in the common pleas court on July 28, 2025, invoking R.C. 2506.01 and appealing from the July 8, 2025 letter . The notice described that decision as having upheld substantiated dispositions under Intake Nos. 3837600, 3810995, and 3760179, and asserted that the agency’s determinations were not supported by reliable, probative, and substantial evidence, were not in accordance with law, and were reached without due process because she was not afforded a meaningful opportunity to contest the allegations. {¶ 11} As to the effect on her rights, the notice alleged that she was denied employment at a mental-health residential facility on August 20, 2024, and that on December 18, 2024, the Ohio Department of Mental Health and Addiction Services confirmed that she would be ineligible to own or operate an agency she had established because she would be considered an employee. The notice cited Ohio Adm.Code 5122-30-31(C)(5) as prohibiting individuals with substantiated findings of abuse or neglect from being employed by or owning a residential facility. A copy of the July 8, 2025 letter was attached, as was a praecipe addressed to the agency requesting a transcript under R.C. 2506.02. The certificate of service stated that the notice was served on CCDCFS by certified mail at 3955 Euclid Avenue. {¶ 12} The docket reflects an attempt at mail delivery of the notice of appeal. A United States Postal Service notification produced August 11, 2025, for item 9314 8001 1300 3551 9220 07, attached as Exhibit A to the agency’s November 25, 2025 reply in support of the motion to dismiss, reported that the item was delivered on August 4, 2025 at 7:15 a.m. in Cleveland, Ohio 44101, and reproduced, under the heading “Signature of Recipient,” a scanned image of the name “Duane Thomas” alongside a printed-name field; the postal document itself neither describes that name as a stamp nor states that no signature was obtained, and the assertions that Duane Thomas (“Thomas”) stamped or printed his name and that no signature was obtained appear in the agency’s November 13, 2025 motion to dismiss and its November 25, 2025 reply in support rather than in the postal record. The accompanying tracking detail records the item as “Delivered, PO Box” in the same zip code. CCDCFS asserts that Thomas is not an employee of the agency, that the agency does not maintain a post office box, and that it is not located within zip code 44101. {¶ 13} CCDCFS moved to dismiss on November 13, 2025 under Civ.R. 12(B)(1), on two grounds: Henderson had not perfected her appeal under R.C. 2505.04 and 2505.07 because the agency never received the notice of appeal within 30 days of the July 8, 2025 letter, and the letter was not a final order under R.C. 2506.01 because it did not determine her rights, duties, privileges, benefits, or legal relationships. The motion was supported by the affidavits of Snider and DeAngelo Royster (“Royster”), attached as Exhibits A and B. Snider attested that the notice of appeal was never delivered to him and that he never received it. Royster, the records room manager and a custodian of records for the agency, attested that he searched the agency’s records and did not locate any notice of appeal and that, to the best of his knowledge, the agency had not received one. Henderson opposed the motion and submitted her own affidavit, in which she stated that she sent the notice of appeal to CCDCFS at its standard mailing address by depositing it in an official United States Postal Service mailbox on July 25, 2025. {¶ 14} That affidavit is not among the documents in the record before this court; the contention that Henderson did not identify the address written on the envelope, the postage applied, the location of the mailbox, or whether the item had been returned as undeliverable appears as an assertion in the agency’s November 25, 2025 reply in support of the motion to dismiss and is repeated in the brief of appellee filed April 9, 2026. She also attached a portion of an email dated December 18, 2024, stating that “the identified record on the Ohio SACWIS report would disqualify you from owning/operating a youth residential class 1 facility for youth.” CCDCFS states that the copy submitted to the trial court had the sender redacted and did not include the record referenced in it. CCDCFS filed a reply on November 25, 2025, and Henderson filed a further response on December 8, 2025. {¶ 15} The trial court granted the motion by journal entry journalized December 15, 2025, which stated: “Appellee CCDCFS’ motion to dismiss, filed 11/13/2025, is granted as this court lacks subject matter jurisdiction and must grant CCDCFS’ motion to dismiss regarding appellant’s R.C. 2506.01 administrative appeal of the July 8, 2025, letter upholding a disposition finding of neglect ‘indicated.’” The court assessed costs to Henderson and directed the clerk to serve the judgment under Civ.R. 58(B). Henderson moved for a stay pending appeal on December 31, 2025, and that motion was denied by journal entry journalized May 29, 2026.  {¶ 16} Henderson filed a timely appeal to this court. In her brief, filed March 12, 2026, she argued that the trial court was incorrect in concluding that it lacked jurisdiction because the July 8, 2025 letter upheld three substantiated dispositions that bar her from working for, or obtaining a license to operate, a youth residential facility. CCDCFS responded on April 9, 2026, arguing that the letter upheld an indicated disposition only and that an indicated finding carries no employment bar under the administrative code, and Henderson filed a reply. On June 5, 2026, CCDCFS filed a notice to correct the record. In that filing, CCDCFS stated that it had argued Henderson’s appeal involved only affirmed indicated findings, but that “counsel for CCDCFS has since learned that the appealed dispositions listed in the July 8, 2025 letter affirmed both indicated and substantiated dispositions.” The filing described the earlier statements as an unintentional, good-faith mistake and stated that the correction does not alter the agency’s position that the trial court lacked subject-matter jurisdiction. {¶ 17} This court released a journal entry and opinion on July 23, 2026, affirming the judgment. On July 25, 2026, Henderson filed an application for reconsideration under App.R. 26(A), contending that the opinion rested on the characterization of the July 8, 2025 order that CCDCFS had corrected before judgment and that the corrected record bears on the jurisdictional analysis under R.C. 2506.01. Attached to the application was a copy of the December 18, 2024 email identifying its sender as the Chief of the License and Certification Bureau of the Ohio Department of Mental Health and Addiction Services. We grant the application, vacate our prior opinion, and issue this opinion in its place, and Appellant is assigning three errors for our review: 1. The administrative appeal process conducted by the Cuyahoga County Division of Children and Family Services violated Appellant’s right to procedural due process by failing to provide adequate notice of the allegations and evidence prior to the appeal meeting; 2. The administrative appeal process violated Appellant’s right to a meaningful opportunity to be heard by preventing Appellant from presenting witnesses, examining evidence, or challenging allegations during the appeal meeting; and 3. The administrative appeal decision lacks sufficient findings of fact and explanation to permit meaningful judicial review. II. Procedural Due Process Notice {¶ 18} Henderson contends that the administrative appeal process conducted by CCDCFS violated her right to procedural due process because the agency did not disclose the allegations or the evidence supporting the dispositions before the appeal meeting. In her appellate brief she frames the claim in three parts: the private interest at stake is substantial because the dispositions recorded in SACWIS bar her from working for or obtaining a license to operate a residential facility for youth under Ohio Adm.Code 5122-30-31(C)(5); the risk of an erroneous deprivation was high because, without notice of the claims, she could not prepare witnesses or gather evidence in response; and the burden on the agency of furnishing that notice would be slight. She further argues in the same assignment of error that the trial court was wrong to conclude that it lacked jurisdiction, because in her view the July 8, 2025 letter upheld dispositions that were substantiated rather than indicated. {¶ 19} CCDCFS responds that the trial court correctly dismissed the appeal for want of subject-matter jurisdiction because the July 8, 2025 letter was not a final order under R.C. 2506.01. In its brief, CCDCFS argued that the letter affirmed only a disposition of neglect “indicated,” but it withdrew that assertion in its Notice to Correct the Record filed June 5, 2026, which states that “the appealed dispositions listed in the July 8, 2025 letter affirmed both indicated and substantiated dispositions.” CCDCFS maintains, notwithstanding the correction, that the letter determined none of Henderson’s rights, duties, privileges, benefits, or legal relationships. {¶ 20} The question that must be answered first is jurisdiction. Henderson invoked the trial court’s authority under R.C. 2506.01, which permits review in the court of common pleas of a “final order, adjudication, or decision” of a division of a political subdivision, and that defines that phrase to mean “an order, adjudication, or decision that determines rights, duties, privileges, benefits, or legal relationships of a person.” R.C. 2506.01(A) and (C). Subject-matter jurisdiction is the power of a court to adjudicate a case; it cannot be waived and may be challenged at any time. Pratts v. Hurley, 2004-Ohio-1980, ¶ 11. When subject-matter jurisdiction is challenged, the party claiming jurisdiction bears the burden of demonstrating that the trial court has jurisdiction over the subject matter. Pivonka v. Corcoran, 2020-Ohio-3476, ¶ 34.  {¶ 21} The Supreme Court of Ohio has held that “a public children-services agency’s disposition on a child-abuse [or neglect] allegation under R.C. 2151.421 is not appealable under R.C. 2506.01, because the disposition does not determine a person’s ‘rights, duties, privileges, benefits, or legal relationships.’” Kyser v. Summit Cty. Children Servs., 2024-Ohio-2898, ¶ 8. The Court explained that “[w]hile certain consequences for a person accused of child abuse may result from an agency’s finding that the abuse allegation is substantiated, the agency’s disposition itself does not determine those consequences.” Kyser at ¶ 2. The immediate consequence of the disposition in that case was that it was noted in SACWIS, and no further consequence was required by R.C. 2151.421; to be final and appealable, an agency’s decision must do more than relate to a person’s rights, duties, privileges, benefits, or legal relationships, because the decision must also fix them conclusively or authoritatively. Kyser at ¶ 15-16. {¶ 22} Kyser thus disposes of the premise on which Henderson’s first assignment of error rests. The disposition at issue in Kyser was a determination that an allegation of abuse was substantiated, and the holding that such a disposition is not appealable under R.C. 2506.01 applies to the July 8, 2025 letter whether the dispositions it affirmed were categorized as “indicated” or as “substantiated.” Henderson’s assertion in her appellate brief that she carries three substantiated findings on her SACWIS record, dated 2001, 2008, and 2015, and the correction supplied by CCDCFS in its Notice to Correct the Record filed June 5, 2026, therefore do not supply the jurisdiction that the trial court found wanting. The characterization of the letter in the journal entry of December 15, 2025, as one “upholding a disposition finding of neglect ‘indicated’” likewise does not alter the analysis, because the jurisdictional bar does not turn on which of the categories in Ohio Adm.Code 5180:2-1-01 the agency selected. {¶ 23} This court applied Kyser in M.F. v. Cuyahoga Cty. Div. of Children & Families, 2024-Ohio-3306 (8th Dist.). The appellant there challenged a disposition letter upholding a substantiated finding of neglect and supported her claim of consequence with an affidavit stating that the owner of a childcare facility had told her she would not be permitted to hire her based on what the appellant had disclosed about her involvement with CCDCFS. This court held that being told she would “not be permitted to” be hired because of her “involvement with CCDCFS” was “too speculative to show that the Disposition Letter in the case at hand determines M.F.’s ‘rights, duties, privileges, benefits, or legal relationships.’” M.F. at ¶ 25. {¶ 24} Henderson seeks to distinguish Kyser and M.F. on the grounds that she came forward with concrete evidence that her inclusion in the SACWIS has affected her ability to obtain licensure. The materials she filed in opposition to the motion to dismiss do not bear that weight. Her affidavit, attached to her response in opposition filed November 14, 2025, addressed only the mailing of her notice of appeal and said nothing about employment or licensure. The single item she offered on the question of consequence was a partial email dated December 18, 2024, with the sender redacted, informing an unidentified recipient that “the identified record on the Ohio SACWIS report would disqualify you from owning/operating a youth residential class 1 facility for youth.” That email predated the July 8, 2025 letter by approximately six months, and the “identified record” to which it referred was not submitted to the trial court. The copy attached to her application for reconsideration filed July 25, 2026 identifies the sender as an employee of the Ohio Department of Mental Health and Addiction Services but still does not identify the record. On this evidence, Henderson did not establish that the July 8, 2025 letter determined her rights, duties, privileges, benefits, or legal relationships, and she therefore did not carry the burden of demonstrating the trial court’s jurisdiction. Pivonka at ¶ 34; M.F. at ¶ 25. {¶ 25} Because the July 8, 2025 letter did not determine Henderson’s rights, duties, privileges, benefits, or legal relationships, it was not a final order under R.C. 2506.01, and the trial court had no subject-matter jurisdiction over her administrative appeal. Kyser at ¶ 8; M.F. at ¶ 25. {¶ 26} That conclusion disposes of the procedural due-process argument advanced under this assignment of error. Subject-matter jurisdiction is the power of a court to adjudicate a case, Pratts, 2004-Ohio-1980, at ¶ 11, and a court that has no such power cannot proceed to decide the claims, constitutional or otherwise, that a party raises within the proceeding. Henderson’s arguments concerning notice of the allegations, access to the investigative materials, and the conduct of the April 1, 2025 appeal meeting all presuppose a forum with authority to review the agency’s process under R.C. 2506.01. Kyser and M.F. establish that the vehicle she selected did not create that forum, and neither the trial court nor this court reaches the merits of those arguments. {¶ 27} We recognize Henderson’s concern that information maintained in SACWIS may affect her future employment and licensing prospects, and nothing in this decision passes upon whether the internal review provided by Ohio Adm.Code 5180:2-33-20 affords the protections she describes. We hold only that R.C. 2506.01, as construed in Kyser, did not vest the trial court with jurisdiction to entertain this appeal or to reach the constitutional question Henderson sought to raise in it. {¶ 28} The first assignment of error is overruled. III. Meaningful Opportunity to be Heard {¶ 29} In her second assignment of error, Henderson contends that the administrative appeal process conducted by CCDCFS violated her right to a meaningful opportunity to be heard because she was not permitted to present witnesses, examine evidence, or challenge the allegations during the administrative appeal meeting that the July 8, 2025 letter states was held on April 1, 2025. {¶ 30} This assignment of error rests on the premise that the trial court had authority to reach the merits of that challenge. As explained in our resolution of the first assignment of error, the trial court determined that it lacked subject- matter jurisdiction under R.C. 2506.01 over Henderson’s appeal from the July 8, 2025 letter, and that determination was correct.  {¶ 31} The Supreme Court of Ohio has held that a public children-services agency’s disposition on a child-abuse allegation under R.C. 2151.421 is not appealable under R.C. 2506.01, because the disposition does not determine a person’s “rights, duties, privileges, benefits, or legal relationships.” Kyser, 2024- Ohio-2898, at ¶ 8. The disposition before the Court in Kyser was one finding a child-abuse allegation substantiated, and the Court explained that the immediate consequence of that disposition was that it was noted in the SACWIS, and that no further consequences were required by R.C. 2151.421. Kyser at ¶ 15. An agency’s decision must do more than relate to a person’s rights, duties, privileges, benefits, or legal relationships; to be final and appealable under R.C. 2506.01(C), the decision must determine them. Kyser at ¶ 16. This court applied Kyser in M.F., 2024-Ohio-3306, at ¶ 25, where the appellant’s evidence that she had been told she would not be permitted to be hired because of her involvement with CCDCFS was too speculative to show that the disposition letter determined her rights, duties, privileges, benefits, or legal relationships. The party claiming jurisdiction bears the burden of demonstrating that the trial court has jurisdiction over the subject matter. Pivonka, 2020-Ohio-3476, at ¶ 34. {¶ 32} The category assigned to the dispositions that were left unchanged does not alter that analysis. In its notice to correct the record filed June 5, 2026, CCDCFS stated that the appealed dispositions listed in the July 8, 2025 letter affirmed both indicated and substantiated dispositions. Kyser addressed a substantiated disposition and held that it was not appealable under R.C. 2506.01. Kyser at ¶ 8. The July 8, 2025 letter accordingly did not determine Henderson’s rights, duties, privileges, benefits, or legal relationships, without regard to whether the dispositions it left unchanged were labeled indicated or substantiated. {¶ 33} Because the July 8, 2025 letter was not a final order appealable under R.C. 2506.01, the trial court was without subject-matter jurisdiction to entertain Henderson’s administrative appeal in any respect, including her challenge to the procedural adequacy of the agency’s appeal meeting. As stated above, subject-matter jurisdiction is the power of a court to adjudicate a case, Pratts, 2004-Ohio-1980, at ¶ 11, and a court that lacks that power cannot reach the merits of the claims presented in the proceeding, including constitutional claims. The trial court therefore had no occasion to consider whether the appeal meeting afforded Henderson notice of the allegations, access to the investigative materials, the opportunity to present witnesses, or the opportunity to challenge adverse information. {¶ 34} Henderson argues in her reply brief that courts retain authority to review whether government procedures comply with constitutional due process even where the administrative decision is not otherwise appealable. The difficulty with that argument is procedural. Henderson invoked the trial court’s authority solely through a notice of appeal filed July 28, 2025, asserting an administrative appeal under R.C. 2506.01. She did not file an independent civil action seeking declaratory or injunctive relief, and she did not invoke any other statutory or original jurisdiction of the trial court. The scope of the proceeding was bounded by R.C. 2506.01, and that statute did not confer jurisdiction over the July 8, 2025 letter for the reasons explained in connection with the first assignment of error and in Kyser and M.F. {¶ 35} The same limitation governs the appeal before us. Because the trial court had no jurisdiction to review the agency’s process, whether the administrative appeal meeting conducted by CCDCFS satisfied the requirements of procedural due process is a question we do not decide in this appeal. {¶ 36} Henderson, appearing pro se, raises concerns about the process as it was applied to her in her own administrative appeal meeting, asserting in her appellant’s brief filed March 12, 2026, that she “was not permitted to review evidence,” that she “could not cross-examine witnesses,” that she “could not subpoena witnesses,” and that she “could not meaningfully challenge the allegations,” and addressing those same procedures again in her reply brief filed April 18, 2026. Nothing in today’s decision passes upon those concerns or forecloses Henderson from pursuing them in a proceeding in which jurisdiction is properly invoked. We hold only that the vehicle Henderson selected, an R.C. 2506.01 appeal from a disposition letter that is not a final order under Kyser, did not place those issues before the trial court or before this court for resolution. {¶ 37} The second assignment of error is overruled. IV. Sufficiency of Findings of Fact {¶ 38} In Henderson’s third assignment of error, she contends that the July 8, 2025 letter lacks sufficient findings of fact and explanation to permit meaningful judicial review. She argues that the decision consists of conclusory statements and that, without specific factual findings identifying the evidence relied upon and the reasoning employed, a reviewing court cannot determine whether the disposition was supported by reliable, probative, and substantial evidence. {¶ 39} This assignment of error presupposes that the trial court had authority to evaluate the substantive adequacy of the agency’s written decision under R.C. 2506.01 and 2506.04. As explained in our resolution of the first assignment of error, the trial court correctly determined that it lacked subject- matter jurisdiction over Henderson’s administrative appeal. Once again, we hold that the July 8, 2025 letter did not determine Henderson’s rights, duties, privileges, benefits, or legal relationships, and it therefore was not a final order under R.C. 2506.01(C). Kyser, 2024-Ohio-2898, at ¶ 8; M.F., 2024-Ohio-3306, at ¶ 25 (8th Dist.). {¶ 40} Because the July 8, 2025 letter was not a final order, the common pleas court had no jurisdiction over the appeal taken from it. Kyser at ¶ 22. It follows that the trial court had no occasion to consider whether the letter identified the evidence the agency relied upon, whether it set out the facts found, or whether it explained how the statutory definition of neglect was satisfied. Those are questions that arise only in an appeal the court has authority to decide. {¶ 41} The trial court’s journal entry journalized December 15, 2025, reflects that limitation. The court granted CCDCFS’s motion to dismiss on the ground that it “lacks subject-matter jurisdiction,” and it made no findings and rendered no judgment concerning the sufficiency of the agency’s factual findings or the adequacy of its written explanation. There is accordingly no substantive ruling on those questions for this court to review. {¶ 42} To the extent Henderson asks this court to remand the matter to CCDCFS for a new administrative hearing accompanied by more detailed findings, that relief is unavailable in this proceeding. Henderson invoked the trial court’s authority solely through an administrative appeal under R.C. 2506.01, and that statute did not reach the July 8, 2025 letter. A court that lacks subject-matter jurisdiction over an action has no power to act in it, and it cannot direct an administrative agency to conduct further proceedings or to supplement its written decision. Pratts, 2004-Ohio-1980, at ¶ 11. Any remedy Henderson may have as to the content of the agency’s decision must be pursued through whatever avenues the statutory and administrative scheme governing public children-services agency dispositions makes available, and not through an appeal under R.C. 2506.01 from an order that statute does not reach. {¶ 43} The third assignment of error is overruled. {¶ 44} Judgment affirmed. It is ordered that appellee recover from appellant costs herein taxed. The court finds there were reasonable grounds for this appeal. It is ordered that a special mandate issue out of this court directing the common pleas court to carry this judgment into execution.  A certified copy of this entry shall constitute the mandate pursuant to Rule 27 of the Rules of Appellate Procedure. ______________________________________ ANITA LASTER MAYS, JUDGE EILEEN T. GALLAGHER, P.J., and SEAN C. GALLAGHER, J., CONCUR