A party does not have three additional days to object to a magistrate's decision when the clerk of court sends the decision by U.S. mail or through a commercial carrier, the Supreme Court of Ohio ruled today.

In a unanimous decision, the Supreme Court held that Christian Wood was one day late in filing his objections to a Lorain County Domestic Relations Court magistrate’s decision that he should pay $25,000 a month in child support.

Wood had been paying $5,000 a month to Jedda Eggleton and objected to the increase. Wood had received a copy of the decision by mail and filed his written objections 15 days after the decision was filed, believing he had three additional days beyond the 14-day response deadline.

Writing for the Court, Chief Justice Sharon L. Kennedy explained the procedural rule that grants three additional days to respond applies to documents served on a party. However, the rule for objecting to magistrate decisions states the response must be submitted 14 days from the date of the decision’s filing.

Viral Image Leads to Relationship
In 2019, a photo of Eggleston went viral on Twitter (now known as X) and received over 7 million views worldwide. It caught Wood’s attention, who used social media to contact Eggleston. Eggleston and Wood dispute the length of their relationship, but they had a child in January 2021.

Later in 2021, Eggleston filed a complaint for child support from Wood in the Lorain County Domestic Relations Court. Wood sought to establish visitation and child support. The parties agreed to an interim child support order for $5,000, which started in July 2021.

In April 2023, a magistrate conducted a trial on the issues of visitation and child support. In December, the magistrate issued a written decision ordering Wood to pay $25,000 a month in child support, backdated to January 2021.

The magistrate determined the child support schedule would support a $2,144-a-month order. However, the $25,000-a-month figure was deemed to be in the best interest of the child, the magistrate found, because of the relative financial resources of the parents. The figure was based on the standard of living the child would have enjoyed if Eggleston and Wood “had stayed together to raise their son.”

Child Support Decision Opposed
The magistrate filed his decision on Dec. 13, 2023, with the clerk of courts. The clerk mailed the decision to the parties on the same day. On Dec. 28, Wood filed his written objections to the decision with the clerk. He also submitted a motion for leave to object, explaining that he believed his objections were not due until Jan. 2, 2024. He requested until Jan. 16 to submit his objections.

The trial court denied the motion. The court found that under Rule 40 of the Ohio Rules of  Juvenile  Procedure, Wood had 14 days to file his objections, which was Dec. 27, not Dec. 28.

Wood appealed the decision to the Ninth District Court of Appeals. Rather than cite the juvenile rules, Wood cited parallel provisions of the Ohio Rules of Civil Procedure. He argued that under Civil Rule 6(D), he  had three additional days to object because the clerk mailed the decision to him. The Ninth District affirmed the trial court’s decision.

Supreme Court Analyzed Filing Rule
Chief Justice Kennedy explained the Court has previously stated Civil Rule 6(D) does not extend the time to file an objection to a magistrate’s decision. The opinion explained that the rule applies when a party has to respond to take some action after the “service” of a notice.

However, Civil Rule 53(D)(3)(b)(i) states that a party may file written objections to a magistrate’s decision within 14 days of the “filing.” The document is filed when it is deposited with the clerk of courts.

Because the time to file an objection to a magistrate’s decision is based on the date it is filed and not when it is served, Wood did not have an additional three days to respond, the opinion stated. The Court affirmed the Ninth District’s decision allowing the trial court to reject Wood’s objections because he missed the deadline.

2024-1791. Eggleston v. Wood, Slip Opinion No. 2025-Ohio-5292.

View oral argument video of this case.

Please note: Opinion summaries are prepared by the Office of Public Information for the general public and news media. Opinion summaries are not prepared for every opinion, but only for noteworthy cases. Opinion summaries are not to be considered as official headnotes or syllabi of court opinions. The full text of this and other court opinions are available online.