The Ohio Supreme Court has ruled that a person fighting a civil stalking protection order must formally object in trial court before trying to challenge it on appeal, or risk losing the chance to contest alleged errors altogether. The decision, handed down Wednesday, stems from a case in which a man identified only as S.P. skipped that step and went straight to the Tenth District Court of Appeals.
What the Court Decided
According to The Lima News, the Supreme Court of Ohio, based in Columbus, decided that a protection-order challenge could not be reviewed without first filing objections in the trial court. The ruling centers on Civ.R. 65.1(G), the rule governing how civil protection orders are issued and contested. Justice Megan Shanahan explained that the rule lays out the procedures for both getting a protection order and fighting one, according to a copy of the opinion published by CourtListener.
Per that opinion, the rule itself makes the consequence explicit: a party who fails to object in trial court “forfeits appellate review” of alleged errors that could have been raised through that objection. S.P. did not file objections to the trial court's adoption of the protection order against him. Instead, he went directly to a notice of appeal, the opinion states.
Jurisdiction Versus Forfeiture
The justices drew a distinction between two separate legal questions: whether the appeals court has jurisdiction to hear the case at all, and whether the appellant preserved the right to challenge specific errors. The court held that failing to file objections under Civ.R. 65.1(G) does not strip a court of appeals of jurisdiction over an appeal from a final protection-order judgment, per the CourtListener opinion. But that same failure still forfeits review of the alleged errors themselves.
That means, under what the opinion calls the majority rule, an appeals court must still proceed with the appeal even though it can only affirm the trial court's issuance of the order once the objections were never filed. The court also noted that Civ.R. 65.1 does not preserve plain-error review for a magistrate's decision granting or denying a civil protection order, according to the same filing.
Affirmed With a Modification
The Supreme Court affirmed the Tenth District's judgment in the case but modified it to reflect the jurisdiction-versus-forfeiture distinction, the opinion states. In practical terms, the appellate court was within its rights to hear S.P.'s appeal, but it could not reach his claimed errors because he never raised them through a trial-court objection first.
Justice Shanahan authored the opinion, which was joined by Chief Justice Sharon L. Kennedy along with Justices R. Patrick DeWine, Joseph T. Deters and Daniel R. Hawkins. Coverage of the ruling from Law360 described the outcome as a case of a pro se litigant who failed to correctly preserve his objections to the stalking protection order against him.
Part of a Broader Pattern
The case fits into a wider conversation among Ohio courts about how civil stalking protection orders are challenged. In a separate matter from December 2025, the Supreme Court agreed to consider a conflict among Ohio courts on related protection-order questions, according to a summary from Court News Ohio. That same account notes that under R.C. 2903.214(C)(1), a person can seek a civil stalking protection order against someone believed to be engaging in menacing-by-stalking behavior.
A party who skips trial-court objections forfeits appellate review of alleged errors that could have been raised by objection. For anyone currently facing or contesting a civil stalking protection order in Ohio, the ruling underscores that the trial-court objection window is not a formality to skip on the way to an appeal.
