On Wednesday, October 1, 2025, the Ohio Supreme Court denied writs of prohibition and mandamus sought by T.B. and A.B. against Franklin County Court of Common Pleas, Division of Domestic Relations, and Juvenile Branch Judge James W. Brown and Magistrate Zeboney Barrañada.
The case, State ex rel. T.B. et al. v. Brown, Judge, et al., case number 2025-Ohio-4484, centered on a dispute regarding the jurisdiction of the juvenile court versus the probate court in matters concerning a minor child, Z.B.
The dispute arose after T.B. and A.B., the proposed adoptive parents of Z.B., filed an adoption petition in the Franklin County Court of Common Pleas, Probate Division. Simultaneously, Z.B.’s birth mother, K.T., filed a motion in the juvenile court seeking visitation time with Z.B. Judge Brown, on March 3, 2025, lifted a stay on the juvenile-court proceedings, reinstated K.T.’s visitation motion, and ordered Magistrate Barrañada to hear the motion.
T.B. and A.B. subsequently filed an original action in the Ohio Supreme Court, arguing that the juvenile court lacked jurisdiction to hear K.T.’s visitation motion because their adoption petition was pending in probate court. They sought a writ of prohibition to prevent Magistrate Barrañada from holding a hearing on the visitation motion and a writ of mandamus to compel Judge Brown to vacate his March 3, 2025, judgment entry.
The Supreme Court, in its per curiam opinion, found that the juvenile court’s actions were within its continuing jurisdiction. The court noted that juvenile courts have exclusive original jurisdiction concerning abused, neglected, or dependent children under R.C. 2151.23(A)(1). Furthermore, R.C. 2151.417(A) allows a juvenile court to review a child’s placement or custody arrangement at any time and to require a parent, guardian, or custodian to take or discontinue actions in the child’s best interest. The court emphasized that this jurisdiction continues until the child turns 18 or is adopted and a final decree is issued, according to R.C. 2151.353(F)(1).
The Supreme Court distinguished this case from State ex rel. Davis v. Kennedy, 2023-Ohio-1593, where a probate court had already issued a preadoption-placement order. In the present case, no such order existed because the proposed adoptive parents were already the legal custodians of Z.B. under a juvenile court order. The court also rejected the argument that the juvenile court’s actions would interfere with the probate court’s determination of Z.B.’s best interest, citing In re Adoption of Ridenour, 61 Ohio St.3d 319 (1991), as inapplicable because there was no evidence that the juvenile court intended to impose post-adoption visitation rights.
The Ohio Supreme Court granted the respondent’s motion to file evidence under seal, citing R.C. 3107.17(B) and Sup.R. 44 regarding the privacy of adoption and juvenile court records. The court concluded that T.B. and A.B. failed to demonstrate that Magistrate Barrañada’s prospective exercise of judicial power was unauthorized or that Judge Brown had a clear legal duty to vacate his March 3, 2025, judgment entry. The writs of prohibition and mandamus were therefore denied.
A copy of the original filing can be found here.
