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Ohio Case Law

Eggleston v. Wood, 2025-Ohio-5292

Case Information

Court: Supreme Court of Ohio
Date: 2025-11-26
Citation: 2025-Ohio-5292
Read the Opinion

Summary

Summary: The Supreme Court of Ohio held that Civ.R. 6(D), which provides an additional three days to respond when documents are served by mail, does not apply to the 14-day deadline to file objections to a magistrate’s decision under Civ.R. 53(D)(3)(b)(i), as that deadline is triggered by the filing of the decision with the clerk, not its service.

Key Holdings

  • Civ.R. 6(D) does not extend the time to object to a magistrate’s decision filed by the clerk and served by mail
  • Time to object under Civ.R. 53(D)(3)(b)(i) begins when the magistrate’s decision is filed not served
  • The Supreme Court of Ohio affirmed the Ninth District’s decision rejecting the extension of time under Civ.R. 6(D)

More Information

This case arose from a child support and visitation dispute initiated by Plaintiff after the parties had a child in 2021. Following a trial, a magistrate ordered Defendant to pay $25,000 per month in child support, a significant upward deviation from the standard schedule, based on the child’s best interests and the financial circumstances and lifestyle the child would have had if the parties had remained together.

Procedurally, the magistrate’s decision was filed on December 13, 2023, and mailed the same day. Defendant filed objections on December 28, one day after the 14-day deadline prescribed by Civ.R. 53(D)(3)(b)(i), which starts upon filing, not service. Defendant argued for a three-day extension under Civ.R. 6(D), which applies to mailed service.

The trial court and Ninth District rejected this argument, concluding that Civ.R. 6(D) did not apply because the deadline to object is tied to the date of filing, not service. The appellate court affirmed that objections were due by December 27.

On discretionary appeal, the Supreme Court affirmed the lower courts. The court reasoned that Civ.R. 6(D) only applies when a deadline is based on service by mail, and since Civ.R. 53(D)(3)(b)(i) sets the deadline from the date of filing, the additional three days do not apply. The decision clarifies that the procedural deadline for objections is strict and does not include mail-based extensions unless explicitly triggered by service.