Griffin v. Muskingum Cty. Job & Family Servs.

[Cite as Griffin v. Muskingum Cty. Job & Family Servs., 2026-Ohio-4044.] IN THE OHIO COURT OF APPEALS FIFTH APPELLATE DISTRICT MUSKINGUM COUNTY, OHIO SEMAJ A. GRIFFIN Case No. CT2026-0008 Plaintiff - Appellant Opinion And Judgment Entry -vs- Appeal from the Court of Common Pleas, Domestic Relations Division, MUSKINGUM COUNTY JOB AND Case No. DG2025-0551 FAMILY SERVICES, ET AL. Judgment: Affirmed Defendants - Appellees Date of Judgment Entry: October 14, 2026 BEFORE: Andrew J. King; Robert G. Montgomery; Kevin W. Popham, Judges APPEARANCES: SEMAJ A. GRIFFIN, PRO SE, for Plaintiff-Appellant; RONALD L. WELCH, MARK A. ZANGHI, AKCHEILA S. CASSADY-HOLLINGSWORTH, PRO SE, for Defendants-Appellees. King, P.J. {¶ 1} Plaintiff-Appellant, Semaj A. Griffin ("Father"), appeals the January 8, 2026 judgment entry of the Muskingum County Domestic Relations Court denying his challenge to an administrative child support order. Defendants-Appellees are Muskingum County Job and Family Services ("Agency") and Akcheila S. Cassady-Hollingsworth ("Mother"). We affirm the trial court. FACTS AND PROCEDURAL HISTORY {¶ 2} This case spans three different dockets. The first case involved Agency filing a contempt motion against Father for failing to submit to genetic testing (Case No. DJ2024- 0391). Personal service was successfully made on July 8, 2024. After eventually complying with genetic testing, Father was deemed father of the subject child. By order dated January 21, 2025, Agency established a child support order for Father to pay to Mother. {¶ 3} On September 19, 2025, Father filed a complaint and motion to vacate void administrative order (DG2025-0551, the underlying case for this appeal). Father challenged the validity and enforceability of the child support order on jurisdictional and procedural grounds. {¶ 4} On September 22, 2025, Agency filed a complaint to enforce the child support order (Case No. DG2025-0553). Personal service was successfully made on December 9, 2025. {¶ 5} A hearing before the trial court on all matters was held on January 7, 2026. By judgment entry filed January 8, 2026, the trial court denied Father's challenge to the administrative order, finding service of the administrative hearing notice to establish child support was properly executed, and determining the order of support was valid and enforceable. {¶ 6} Father filed an appeal with the following assignments of error: I {¶ 7} "THE TRIAL COURT ERRED AS A MATTER OF LAW BY EXERCISING JURISDICTION WITHOUT FIRST RESOLVING APPELLANT'S JURISDICTIONAL CHALLENGE." II {¶ 8} "THE TRIAL COURT ERRED BY ENFORCING AND ADJUDICATING AN ADMINISTRATIVE CHILD SUPPORT ORDER THAT WAS NEVER ADOPTED AS A JUDGMENT OF THE COURT."  III {¶ 9} "THE TRIAL COURT VIOLATED APPELLANT'S RIGHT TO DUE PROCESS BY FAILING TO REQUIRE COMPETENT EVIDENCE OF SERVICE AND BY RELYING ON INCOMPLETE OR RECONSTRUCTED RECORDS." IV {¶ 10} "THE TRIAL COURT IMPROPERLY SHIFTED THE BURDEN OF PROOF TO APPELLANT IN A JURISDICTIONAL CHALLENGE." V {¶ 11} "THE TRIAL COURT'S JUDGMENT IS LEGALLY DEFICIENT FOR FAILURE TO ISSUE ADEQUATE FINDINGS OF FACT AND CONCLUSIONS OF LAW ON DISPOSITIVE ISSUES." I, III, IV {¶ 12} In Father's first, third, and fourth assignments of error, he claims the trial court erred by finding jurisdiction and proper service, and shifting the burden of proof to him in his jurisdictional challenge. We disagree. {¶ 13} "Personal jurisdiction is a question of law that appellate courts review de novo." Kauffman Racing Equipment, L.L.C. v. Roberts, 2010-Ohio-2551, ¶ 27; accord Mangan v. Morocho & Garcia Construction, LLC, 2024-Ohio-2241, ¶ 10 (10th Dist.). The plaintiff bears the burden of securing proper service. Cincinnati Insurance Co. v. Emge, 124 Ohio App.3d 61, 63 (1st Dist. 1997). "Where the plaintiff follows the civil rules governing service of process, courts presume that service is proper unless the defendant rebuts this presumption with sufficient evidence of non-service. In order to rebut the presumption of proper service, the other party must produce evidentiary-quality information demonstrating that he or she did not receive service." (Citations omitted.) Hook v. Collins, 2017-Ohio-976, ¶ 14 (8th Dist.). {¶ 14} Prior to the administrative child support hearing, Father was ordered to submit to genetic testing to establish paternity. Service of process for that proceeding was undisputed. See Summons in Contempt Returned and Filed in Case No. DJ2024-0391. During the hearing on all matters, the trial court gave Father the opportunity to raise his concerns over jurisdiction. He argued defective service because the "administrative order [hearing notice] was served via regular mail instead of certified mail or personal service" and therefore the child support order was void. January 7, 2026 T. at 3. Father refused to answer any of the trial court's questions, repeatedly asserted defective service, and was unable to give the trial court any legal basis to support his arguments. Id. at 4-8. Father admitted to receiving a copy of the administrative hearing notice via regular mail. Id. at 28. {¶ 15} In its January 8, 2026 judgment entry, the trial court noted Father's objections to the support order related to service of the notice setting the administrative child support hearing; he did not object to the calculation of support, the support order, or the wage withhold in effect. The trial court then determined the following: However, pursuant to OAC 5101:12-30-10 (C)(2), the administrative order finding paternity is to be served by ordinary, first class mail to the last known address of the person to be served, and OAC 5101:12-30-10 (C)(3)(a) provides that, "[i]n accordance with section 3111.80 of the Revised Code, if notice of the administrative hearing to determine child support is attached to the administrative order establishing paternity, service shall be made by  ordinary, first class mail to the last known address of the person to be served as allowed by section 3111.46 of the Revised Code." The CSD records establish JFS Form 07774 CSEA Administrative Order Establishment of Paternity was sent by ordinary mail to the parties, together with notice of the administrative hearing to establish support (JFS Form 07782) December 5, 2024. Thus, ordinary mail was appropriate to inform plaintiff and defendant Cassady-Hollingsworth of the hearing. Plaintiff does not dispute that he received notice by ordinary mail; he believed the CSD was required to issue service by certified mail or personal service for any subsequent support order to be valid. {¶ 16} The trial court concluded notice of the administrative child support hearing was properly served and the resulting order was valid and enforceable. Father has produced no argument to challenge the Administrative Code sections cited by the trial court. What Father is arguing is that the trial court was not permitted to hear anything on substantive matters at the hearing "without first resolving whether jurisdiction existed." Appellant's Brief at 8. He argues he made "multiple jurisdictional objections during the hearing, including challenges beyond the issue of service," but does not identify them. Id. at 9. A review of the hearing transcript does not indicate "challenges beyond the issue of service." Father further argues the trial court relied on an incomplete and unsubstantiated administrative record, but does not indicate what necessary documents were missing from the record. Appellant's Brief at 15. He did not present any evidence to successfully rebut the presumption of proper service.  {¶ 17} Interestingly, Father argues the trial court lacked personal jurisdiction, yet subjected himself to the jurisdiction of the trial court when he filed the underlying action to the court on September 19, 2025. {¶ 18} Upon review, we find the trial court did not err by finding jurisdiction and proper service. {¶ 19} Assignments of Error I, III, and IV are denied. II {¶ 20} In Father's second assignment of error, he claims the trial court erred in enforcing and adjudicating an administrative child support order that was never adopted as a judgment of the court. We disagree. {¶ 21} Following an administrative hearing, the administrative officer may issue an order of support for a child, and the order "shall take effect fourteen days after the order is issued." R.C. 3111.81 and 3111.84; see also Adm.Code 5101:12-45-05.3(C). The General Assembly has not mandated that a trial court must adopt the administrative order as a judgment of the court before enforcing it. {¶ 22} Upon review, we find the trial court did not err in enforcing the child support order even though it was never adopted as a judgment of the court as argued by Father. {¶ 23} Assignment of Error II is denied. V {¶ 24} In Father's fifth assignment of error, he claims the trial court failed to issue adequate findings of fact and conclusions of law on dispositive issues. We disagree. {¶ 25} Father does not offer any argument on this assignment of error. He does not state which dispositive issues the trial court failed to adequately address. The only issues he challenged were jurisdiction and service and the trial court completely addressed those issues. Further, Father did not request any findings of fact and conclusions of law. {¶ 26} Upon review, we find the trial court did not fail to adequately rule on the contested issues. {¶ 27} Assignment of Error V is denied. {¶ 28} For the reasons stated in our accompanying Opinion, the judgment of the Muskingum County Domestic Relations Court is AFFIRMED. {¶ 29} Costs to Appellant. By: King, P.J. Montgomery, J. and Popham, J. concur.