Prohibition, Sovereign‑Citizen Trust Gambits, and Adequate Remedies in Ohio Child‑Support Enforcement:
Commentary on Seelbaugh v. Montgomery Cty. Court of Common Pleas, Domestic Relations Div., 2025‑Ohio‑5297

I. Introduction

The Supreme Court of Ohio’s per curiam decision in Seelbaugh v. Montgomery County Court of Common Pleas, Domestic Relations Division, 2025‑Ohio‑5297, is a compact but important reaffirmation of several procedural and jurisdictional principles:

A court of common pleas (and its divisions) is not sui juris and cannot be sued as an entity.
Sovereign‑citizen‑style attempts to evade domestic‑relations jurisdiction by resort to trusts and “estate” constructs are legally ineffective.
Alleged due‑process defects in the structure of Title IV‑D child‑support enforcement do not create a patent and unambiguous lack of jurisdiction.
Opportunities to object to a magistrate’s decision and to pursue administrative and judicial review of CSEA actions are “adequate remedies in the ordinary course of law” that bar the extraordinary writ of prohibition.
Pro se litigants are held to the same standards as represented parties, including compliance with local rules governing security deposits and indigency affidavits.

The case arises out of a child‑support contempt finding and an administrative default determination by a county child support enforcement agency (“CSEA”) in the context of a domestic‑relations matter. The relator, acting both individually and as grantor/trustee of a revocable living trust, sought a writ of prohibition from the Second District Court of Appeals to halt and undo those determinations. When the court of appeals dismissed his action under Civ.R. 12(B)(6), he appealed as of right to the Supreme Court of Ohio, which affirmed.

While the decision does not break entirely new doctrinal ground, it synthesizes and reiterates a series of rules that are particularly salient for domestic‑relations courts, CSEAs, and litigants—especially those invoking sovereign‑citizen‑type arguments and those attempting to use extraordinary writs as substitutes for ordinary review mechanisms.

II. Factual and Procedural Background

A. Underlying domestic‑relations and child‑support proceedings

Christopher P. Seelbaugh was the defendant in divorce proceedings in the Domestic Relations Division of the Montgomery County Court of Common Pleas. Pursuant to the divorce order, he was obligated to pay child support. When he failed to comply:

His former spouse moved to have him held in contempt for nonpayment of child support.
A domestic‑relations‑court magistrate found him in contempt.
The Montgomery County CSEA determined that he was in default under the child‑support order and issued income‑withholding orders.

B. The prohibition action in the Second District Court of Appeals

In October 2024, instead of pursuing the avenues of relief built into the child‑support and domestic‑relations systems (objections, appeals, administrative review, etc.), Seelbaugh filed an original action in prohibition in the Second District Court of Appeals. He named as respondents:

The Montgomery County Court of Common Pleas, Domestic Relations Division (“domestic‑relations court”); and
The Montgomery County Child Support Enforcement Agency (“CSEA”).

He later filed an amended petition asserting four claims:

Lack of personal jurisdiction – He alleged that the domestic‑relations court lacked personal jurisdiction over him because service of process was directed to his “estate” held in a trust, rather than to him personally.
Probate court’s “exclusive” jurisdiction – He maintained that, because his assets were held in a trust, any enforcement of child‑support obligations must proceed exclusively in the probate court, depriving the domestic‑relations court of subject‑matter jurisdiction.
Structural due‑process defect in Title IV‑D magistrate arrangements – He argued that the domestic‑relations court’s contract with the CSEA for magistrate services in Title IV‑D cases created structural incentives (essentially, compensation tied to the volume of child‑support work) that deprived him of due process and thereby stripped the court of jurisdiction.
Due‑process challenge to CSEA’s quasi‑judicial role – He similarly claimed that the CSEA, acting in a quasi‑judicial capacity through administrative hearings, operated under an improper contractual arrangement with the domestic‑relations court that violated due process and removed CSEA’s jurisdiction.

As relief, he asked the Second District to:

Vacate the magistrate’s contempt decision;
Vacate the CSEA’s default decision; and
Prohibit any further proceedings by the domestic‑relations court or CSEA in his matters.

The domestic‑relations court and the CSEA moved to dismiss the amended petition under Civ.R. 12(B)(6). The Second District granted both motions and dismissed the action, relying on several grounds:

Improper respondent (the domestic‑relations court as a non‑sui‑juris entity);
Failure to show a patent and unambiguous lack of jurisdiction;
Existence of adequate remedies in the ordinary course of law; and
Noncompliance with local rules regarding the filing fee or affidavit of indigency.

From that dismissal, Seelbaugh appealed as of right to the Supreme Court of Ohio, assigning five errors corresponding to these grounds.

III. Summary of the Supreme Court’s Opinion

The Supreme Court of Ohio, in a unanimous per curiam opinion, affirmed the Second District’s dismissal. The Court held:

The domestic‑relations division is not a proper respondent. As a division of the court of common pleas, it is not sui juris and cannot be sued. Naming an entity that cannot be sued is itself a sufficient reason to dismiss the action as to that entity. Pro se status does not excuse this defect.
No patent and unambiguous lack of jurisdiction. The domestic‑relations court possessed subject‑matter jurisdiction over divorce and child‑support matters under R.C. 3105.011, and the CSEA had statutory authority under R.C. Chapter 3123 and R.C. 3125 to investigate defaults and conduct administrative hearings. The relator’s contentions—based on trust constructs and alleged due‑process violations in Title IV‑D arrangements—did not demonstrate a patent and unambiguous lack of jurisdiction.
Sovereign‑citizen–style trust arguments fail. Attempts to treat the trust as a separate entity to insulate the relator from the domestic‑relations court’s reach were characterized as “sovereign‑citizen arguments,” which are legally untenable as jurisdictional challenges.
Adequate remedies precluded prohibition. Even absent a patent lack of jurisdiction, the writ of prohibition is unavailable because:
- For the CSEA default determination, the relator had statutory rights to an administrative hearing and then to a court hearing (R.C. 3123.04 and 3123.05).
- For the magistrate’s contempt decision, he could file objections under Civ.R. 53(D)(3)(b), and then appeal after the domestic‑relations judge adopted the decision.
- The Court explicitly reiterates that an opportunity to file objections to a magistrate’s decision is an adequate remedy in the ordinary course of law.
Failure to comply with local rules regarding filing fees/indigency. The record contained no affidavit of indigency accompanying the petition, and no record support for the relator’s assertion that he had in fact filed one. Consequently, the court of appeals properly determined he did not comply with Second Dist.Loc.R. 2 and could dismiss on that independent basis.

Collectively, these holdings foreclose the use of prohibition to collaterally attack routine domestic‑relations and CSEA actions where Ohio’s statutory and procedural frameworks already provide comprehensive review mechanisms.

IV. Detailed Analysis of the Court’s Legal Reasoning

A. Standard of Review and Prohibition Framework

The Court begins by restating key principles governing Civ.R. 12(B)(6) dismissals in extraordinary writ cases:

De novo review – The Supreme Court reviews a court of appeals’ dismissal under Civ.R. 12(B)(6) de novo. (State ex rel. Martre v. Cheney, 2023‑Ohio‑4594, ¶ 16).
Writ of prohibition elements – To obtain a writ of prohibition, a relator must prove by clear and convincing evidence:
1. The respondent court or agency is about to exercise or has exercised judicial or quasi‑judicial power;
2. The respondent lacks authority to exercise that power; and
3. The relator has no adequate remedy in the ordinary course of law.
(Citing State ex rel. Reynolds v. Kirby, 2023‑Ohio‑782, ¶ 9).
Patent and unambiguous lack of jurisdiction – When the relator seeks to undo completed actions, he must demonstrate that the respondent patently and unambiguously lacked jurisdiction to act. If such a patent lack is shown, he need not establish the absence of adequate remedies. (State ex rel. Rarden v. Butler Cty. Common Pleas Court, 2023‑Ohio‑3742, ¶ 10).

Under this framework, the Court analyzes both the jurisdictional arguments (subject‑matter and personal jurisdiction) and the availability of ordinary remedies.

B. The Domestic‑Relations Court as an Improper Respondent (Non‑Sui‑Juris Courts)

In addressing the first assignment of error, the Court reaffirms a procedural rule of considerable importance:

The Domestic Relations Division is not an independent juridical entity but a division of the Montgomery County Court of Common Pleas (R.C. 3105.011).
A court of common pleas is “not sui juris”—it is not a legal entity capable of being sued in its own name. The Court relies on State ex rel. Smith v. Hamilton Cty. Court of Common Pleas, 2024‑Ohio‑2779, ¶ 7.

Thus, by naming the domestic‑relations court as respondent, the relator sued an entity that cannot be sued. As the Court succinctly puts it, “[a] relator’s naming an entity that cannot be sued is a sufficient basis for dismissal of the relator’s action as to that entity.”

Critically, the relator argued that his pro se status required the court of appeals to overlook this misnomer and “liberally construe” his filings. The Court rejects that contention, citing In re Application of Black Fork Wind Energy, L.L.C., 2013‑Ohio‑5478, ¶ 22, for the proposition that:

A pro se litigant is presumed to know the law and legal procedures and is held to the same standard as a litigant represented by counsel.

This is a clear warning to self‑represented litigants: the rules governing proper parties and capacity to be sued apply equally to them. Errors in naming an improper respondent will not be excused solely on account of pro se status.

C. Rejection of Sovereign‑Citizen–Style Trust Arguments

The heart of the second and third assignments of error is the contention that:

The domestic‑relations court lacked subject‑matter jurisdiction because assets were held in a trust allegedly subject to probate court’s exclusive jurisdiction; and
The court lacked personal jurisdiction because service was allegedly directed at his “estate” or trust rather than at him personally.

The Court characterizes these arguments as “in essence, sovereign‑citizen arguments.” It cites:

Sec. Credit Servs., L.L.C. v. Miller, 2024‑Ohio‑3371 (11th Dist.), describing the theory of sovereign‑citizen defenses;
Young v. Young, 2023‑Ohio‑3918 (5th Dist.), rejecting similar attempts to claim that the creation of a trust severed jurisdiction over the individual; and
SoFi Lending Corp. v. Williams, 2024‑Ohio‑1166 (8th Dist.), holding that an individual cannot hide behind created entities to defeat jurisdiction.

Sovereign‑citizen litigants often assert that by placing their assets in a trust, or by creating elaborate alternate identities (e.g., “the estate of <name>”), they can treat their “legal person” as distinct from their “natural person” and thereby evade courts’ jurisdiction. The Court squarely rejects this:

“Sovereign‑citizen arguments may not be used to challenge a court’s jurisdiction.” (Citing Furr v. Ruehlman, 2023‑Ohio‑481).
“A person cannot shield himself from a court’s jurisdiction by creating a trust.” (following Young at ¶ 21‑22).

This rejection is both substantive and categorical: such theories are not merely incorrect; they are non‑cognizable as jurisdictional challenges. The use of trust instruments does not displace the domestic‑relations court’s authority over divorce, child support, and enforcement against the obligor.

D. Subject‑Matter and Personal Jurisdiction of the Domestic‑Relations Court

1. Subject‑matter jurisdiction

On subject‑matter jurisdiction, the Court reiterates the basic test:

When a court has the constitutional or statutory power to adjudicate a particular class or type of case, that court has subject‑matter jurisdiction. (Ostanek v. Ostanek, 2021‑Ohio‑2319, ¶ 36).

The legislature has expressly granted domestic‑relations divisions “full equitable powers and jurisdiction appropriate to the determination of all domestic relations matters.” R.C. 3105.011(A). As the Court explains:

Domestic‑relations divisions have subject‑matter jurisdiction over divorce actions and the division of marital property (Ostanek, ¶ 36).
R.C. 3105.011(B) further supports broad jurisdiction in domestic‑relations matters.

Because the underlying actions involve divorce and child support, the domestic‑relations court’s subject‑matter jurisdiction is clear and unaffected by the mere presence of a trust in the obligor’s financial arrangements.

2. Personal jurisdiction and defective service arguments

Prohibition based on alleged lack of personal jurisdiction is “extremely rare.” The Court cites LG Chem, Ltd. v. Goulding, 2022‑Ohio‑2065, ¶ 9, to emphasize the limited scope of such relief.

Where a relator claims that service of process is defective, the Court applies a narrow rule (quoting State ex rel. Suburban Constr. Co. v. Skok, 1999‑Ohio‑329):

When a prohibition claim is predicated on defective service, if contested allegations of defective service of process are not premised upon a complete failure to comply with the minimum‑contacts requirement of constitutional due process, prohibition does not lie. (Lundeen v. Turner, 2021‑Ohio‑1533, ¶ 17, quoting Suburban Constr.).

Here, the relator did not allege any complete failure of minimum contacts; rather, he focused on technical and conceptual distinctions between himself and his “estate in trust.” This is far from the kind of extreme lack of personal jurisdiction that could justify prohibition.

Thus, the Court holds that his personal‑jurisdiction claim cannot support a writ of prohibition.

E. Due‑Process Attacks on Title IV‑D Magistrate and CSEA Structures

The relator also argued that the domestic‑relations court and CSEA lost jurisdiction because their contractual arrangements under Title IV‑D of the Social Security Act allegedly created structural due‑process violations:

Magistrates compensated, he claimed, based on time spent on child‑support cases, allegedly creating an improper incentive to sustain enforcement actions;
CSEA’s quasi‑judicial role in administrative hearings under a similarly “tainted” arrangement with the court.

The Court responds to these arguments with a jurisdictional–procedural distinction:

Statutory authority – The domestic‑relations court has statutory subject‑matter jurisdiction over divorce and child‑support matters (R.C. 3105.011). Magistrates may be appointed in Title IV‑D matters under R.C. 3125.60.
CSEA’s statutory authority – Each county must have a CSEA (R.C. 3125.10), whose duties include:
- Investigating defaults under child‑support orders (R.C. 3123.02, 3123.03); and
- Conducting administrative hearings on such defaults (R.C. 3123.04).
Due process ≠ jurisdiction – Even if there are alleged due‑process defects in how a court or agency exercises its authority, those defects do not, without more, oust jurisdiction. The Court relies on State ex rel. Ames v. Ondrey, 2023‑Ohio‑4188, ¶ 14, which held that weaving due‑process allegations into jurisdictional arguments does not convert non‑jurisdictional claims into jurisdictional ones; such issues are addressable on appeal, not via prohibition.

In other words, challenges to the fairness or structure of the child‑support enforcement apparatus—whether against magistrates or CSEA—are matters for direct appeal or other ordinary remedies, not for extraordinary prohibition, absent a patent and unambiguous lack of statutory authority.

F. Adequate Remedies in the Ordinary Course of Law

Once the Court concluded that neither the domestic‑relations court nor the CSEA patently lacked jurisdiction, the relator faced a high bar: he had to show a lack of adequate remedies in the ordinary course of law. He could not meet this requirement.

1. General standard

An alternate remedy is adequate when it is “complete, beneficial, and speedy.” (State ex rel. Jones v. Paschke, 2024‑Ohio‑135, ¶ 17, quoting State ex rel. Gilmour Realty, Inc. v. Mayfield Hts., 2008‑Ohio‑3181, ¶ 14). If such a remedy exists, prohibition is not available. (State ex rel. Drouhard v. Morrow Cty. Bd. of Commrs., 2020‑Ohio‑4160, ¶ 19).

2. Remedies regarding the CSEA default determination

The statutory scheme gives obligors multiple layers of review:

Administrative hearing before CSEA – Under R.C. 3123.04, an obligor who receives a default notice can request an administrative hearing.
Court hearing after administrative review – If dissatisfied with the administrative outcome, the obligor can file a motion for a court hearing under R.C. 3123.05.

The default notice attached to the relator’s amended petition expressly notified him of these rights. These procedures are comprehensive, designed to be “complete, beneficial, and speedy” and thus constitute adequate remedies.

3. Remedies regarding the magistrate’s contempt decision

For the contempt finding by the domestic‑relations magistrate:

Objections to the magistrate’s decision – Civ.R. 53(D)(3)(b) allows a party to file written objections to a magistrate’s decision. The Supreme Court explicitly states that an opportunity to file such objections is an adequate remedy in the ordinary course of law, relying on State ex rel. Nalls v. Russo, 2002‑Ohio‑4907, ¶ 27, 30.
Appeal after adoption by the judge – A magistrate’s decision is not effective until adopted by the trial court (Civ.R. 53(D)(4)(a)). Once the domestic‑relations judge adopts the decision, the party can appeal. An appeal is generally an adequate remedy that precludes a writ of prohibition. (State ex rel. Smith v. Hall, 2016‑Ohio‑1052, ¶ 8.)

The Court also reiterates a crucial point from State ex rel. O’Malley v. Collier‑Williams, 2018‑Ohio‑3154, ¶ 13: the fact that a party does not obtain a favorable decision in the ordinary course does not render the remedy inadequate. Adequacy is measured by the existence and general efficacy of the procedure, not by outcome.

Given these multiple avenues of review, the relator had ample ordinary remedies and therefore could not obtain the extraordinary writ of prohibition.

G. Noncompliance with Local Rules on Security Deposits and Indigency

As a separate and independent basis for affirmance, the Court addresses the relator’s failure to comply with the Second District’s local rules governing filing fees and indigency.

Second Dist.Loc.R. 2 requires either payment of a security deposit (filing fee) or the submission of an affidavit of indigency.
The relator claimed he had filed such an affidavit with his petition and tried to correct the record with a Civ.R. 60(A) motion.
The record, however, contained no affidavit attached to the original or amended petition, and no indication that one had been filed but omitted from the docket.

In these circumstances, the Supreme Court agrees that the court of appeals correctly held the relator failed to comply with its local rule. This failure alone justified dismissal, independently of the jurisdictional and adequate‑remedy analysis.

V. Precedents Cited and Their Influence

The opinion draws on a suite of prior decisions to anchor its conclusions. The most significant are:

A. Writ‑of‑Prohibition and Adequate‑Remedy Cases

State ex rel. Martre v. Cheney, 2023‑Ohio‑4594 – Confirms the de novo standard of review for Civ.R. 12(B)(6) dismissals in writ actions and the rule that dismissal is appropriate when, taking all factual allegations as true, the relator can prove no set of facts entitling him to relief.
State ex rel. Reynolds v. Kirby, 2023‑Ohio‑782 – Provides the three‑part test for entitlement to a writ of prohibition (exercise of power, lack of authority, and lack of adequate remedy).
State ex rel. Rarden v. Butler Cty. Common Pleas Court, 2023‑Ohio‑3742 – Clarifies that when a relator seeks to undo prior judicial or quasi‑judicial actions, he must show a patent and unambiguous lack of jurisdiction; if that is shown, he need not prove the absence of adequate remedies.
State ex rel. Drouhard v. Morrow Cty. Bd. of Commrs., 2020‑Ohio‑4160 – Reiterates that the adequacy of remedies in the ordinary course precludes extraordinary relief.
State ex rel. Jones v. Paschke, 2024‑Ohio‑135, and State ex rel. Gilmour Realty, Inc. v. Mayfield Hts., 2008‑Ohio‑3181 – Provide the “complete, beneficial, and speedy” test for evaluating adequacy of alternate remedies.

B. Jurisdiction, Sovereign‑Citizen Theories, and Domestic‑Relations Authority

State ex rel. Smith v. Hamilton Cty. Court of Common Pleas, 2024‑Ohio‑2779 – Establishes that a court of common pleas is not sui juris, forming the basis for dismissing the domestic‑relations division as an improper respondent.
In re Application of Black Fork Wind Energy, L.L.C., 2013‑Ohio‑5478 – Confirming that pro se litigants are held to the same standards as those represented by counsel.
Sec. Credit Servs., L.L.C. v. Miller, 2024‑Ohio‑3371 (11th Dist.) – Describes the nature of sovereign‑citizen arguments.
Young v. Young, 2023‑Ohio‑3918 (5th Dist.) – Rejects the notion that creating a trust deprives a domestic‑relations court of jurisdiction over the individual and his property interests for purposes of matrimonial and support obligations.
SoFi Lending Corp. v. Williams, 2024‑Ohio‑1166 (8th Dist.) – Holds that a person cannot hide behind created entities to avoid the jurisdiction of a court.
Furr v. Ruehlman, 2023‑Ohio‑481 – Determines that sovereign‑citizen defenses are not cognizable in mandamus, a principle extended here to prohibition.
Ostanek v. Ostanek, 2021‑Ohio‑2319, and State ex rel. Gray v. Kimbler, 2022‑Ohio‑3937 – Confirm the broad subject‑matter jurisdiction of domestic‑relations courts over divorce, child support, and related equitable matters pursuant to R.C. 3105.011.

C. Personal Jurisdiction and Service‑of‑Process Cases

LG Chem, Ltd. v. Goulding, 2022‑Ohio‑2065 – Observes that prohibition to contest personal jurisdiction is “extremely rare,” limiting the scope for this type of writ.
Lundeen v. Turner, 2021‑Ohio‑1533, and State ex rel. Suburban Constr. Co. v. Skok, 1999‑Ohio‑329 – Establish that prohibition will not lie when defective service allegations are not premised on a complete lack of minimum contacts for due‑process purposes.

D. Due Process vs. Jurisdiction

State ex rel. Ames v. Ondrey, 2023‑Ohio‑4188 – Holds that embedding due‑process claims within “jurisdictional” rhetoric does not convert them into true jurisdictional challenges; such claims are cognizable on appeal, not via extraordinary writ.

E. Remedies via Magistrate Objections and Appeal

State ex rel. Nalls v. Russo, 2002‑Ohio‑4907 – Recognizes that objections to a magistrate’s decision constitute an adequate remedy at law that precludes prohibition.
State ex rel. Smith v. Hall, 2016‑Ohio‑1052 – Confirms that appeal from a trial court judgment adopting a magistrate’s decision is an adequate remedy that generally bars prohibition.
State ex rel. O’Malley v. Collier‑Williams, 2018‑Ohio‑3154 – Emphasizes that an inadequate result does not make a remedy inadequate; the relevant question is whether the remedy mechanism exists and is reasonably effective.

Together, these authorities strongly reinforce the Court’s refusal to let extraordinary writs become vehicles for relitigating, avoiding, or preempting normal processes of review in domestic‑relations and child‑support matters.

VI. Impact and Practical Significance

A. For Domestic‑Relations Courts and CSEAs

The decision fortifies:

The independence and validity of domestic‑relations jurisdiction against attempts to reroute child‑support enforcement into probate or other forums based on trust formations or sovereign‑citizen theories.
The legitimacy of existing Title IV‑D structures, including magistrate appointments and CSEA quasi‑judicial processes, so long as they remain within statutory bounds. Procedural or due‑process challenges must be litigated via objections and appeals, not through extraordinary writs.

B. Deterrence of Sovereign‑Citizen Tactics

By explicitly labeling the relator’s trust‑based jurisdictional theories as “sovereign‑citizen arguments” and holding them non‑cognizable, the Court sends a clear message:

Domestic‑relations and trial courts may treat such theories as frivolous or legally irrelevant at the jurisdictional stage.
Attempting to avoid child‑support obligations via artificial legal constructs (trusts, “estates,” dual personhood, etc.) will not succeed in Ohio’s courts.

C. Reinforcing the “Extraordinary” Nature of Prohibition

The Court’s insistence on:

A strict requirement of patent and unambiguous lack of jurisdiction for undoing completed actions; and
A broad conception of what counts as an “adequate remedy in the ordinary course of law”;

strengthens the boundary between extraordinary and ordinary remedies. Prohibition is not a back door to review when adverse rulings can be challenged through objections, administrative review, or direct appeal.

D. Procedural Compliance and Pro Se Litigants

The case underscores that:

Local rules regarding filing fees and indigency affidavits are not optional; failure to comply can be fatal to an original action.
Pro se litigants are not entitled to laxer standards in naming proper respondents or complying with procedural prerequisites.

This will likely be cited in future cases to support strict enforcement of filing requirements, even against unrepresented parties.

VII. Complex Concepts Simplified

To make the opinion accessible, several core concepts deserve plainer explanation.

A. Writ of Prohibition

A writ of prohibition is an extraordinary remedy used to stop a court or quasi‑judicial body from acting outside its jurisdiction. It is:

Preventive (to stop future unauthorized acts) and, only rarely,
Corrective (to undo actions already taken), and then only if the agency or court clearly had no jurisdiction.

It is not a substitute for an appeal, nor is it a general error‑correction tool.

B. “Patent and Unambiguous” Lack of Jurisdiction

This means that the lack of authority is obvious, clear on the face of the law, and not subject to reasonable debate. If there is any arguable basis for jurisdiction, or if the alleged defect concerns how jurisdiction is exercised rather than whether it exists, prohibition usually fails.

C. Subject‑Matter vs. Personal Jurisdiction

Subject‑matter jurisdiction – A court’s power to hear cases of a particular type (e.g., divorces, child support). For domestic‑relations courts, this comes from statutes like R.C. 3105.011.
Personal jurisdiction – A court’s power over the particular parties in the case, typically based on ties to the state (residence, presence, contacts) and proper service of process.

Defects in subject‑matter jurisdiction are fundamental and can sometimes support extraordinary relief. Defects in personal jurisdiction, especially minor or contested service issues, rarely justify prohibition.

D. Adequate Remedy in the Ordinary Course of Law

A remedy is “adequate” if there is a standard, available process—such as:

Administrative hearings;
Objections to a magistrate’s decision;
Appeals; or
Other statutory review mechanisms;

that is reasonably complete, beneficial, and speedy. The existence of such a remedy almost always bars a writ of prohibition.

E. Title IV‑D and CSEA

Title IV‑D of the Social Security Act (42 U.S.C. 651 et seq.) is a federal scheme encouraging states to establish efficient child‑support enforcement programs, with federal funding tied to performance. Ohio implements this through:

County Child Support Enforcement Agencies (CSEAs), established under R.C. 3125.10;
Statutory duties to detect and address defaults (R.C. 3123.02, 3123.03); and
Administrative hearings with subsequent court review (R.C. 3123.04, 3123.05).

Magistrates can be appointed to handle Title IV‑D cases under R.C. 3125.60. Challenges to the operation of this system are usually litigated within that framework, not via extraordinary writs.

F. Sovereign‑Citizen Arguments

“Sovereign‑citizen” is an umbrella term for various pseudo‑legal theories claiming individuals can opt out of government authority through:

Special wording or filings;
Trusts, “estates,” or corporate shells;
Declarations of “sovereign” or “national” status.

Courts uniformly reject these theories as legally baseless. Such arguments cannot defeat jurisdiction or excuse compliance with court orders, including child‑support obligations.

G. “Court Not Sui Juris”

“Sui juris” means “of its own right.” When a court is said to be “not sui juris,” it means the institution itself is not a separate legal person that can be sued; rather, actions must be brought against appropriate officers or entities (e.g., judges in their official capacities, the clerk, the county, etc.).

H. Magistrate’s Decision, Objections, and Adoption

A magistrate is a judicial officer who conducts hearings and issues recommended decisions.
Parties may file objections to the magistrate’s decision under Civ.R. 53(D)(3)(b), asking the judge to review and correct errors.
The decision does not take effect until the trial judge adopts it (Civ.R. 53(D)(4)(a)), at which point it becomes the court’s judgment and is generally appealable.

This layered process (magistrate decision → objections → adoption → appeal) is designed to provide a robust set of ordinary remedies, obviating the need for extraordinary writs in most circumstances.

VIII. Conclusion: Key Takeaways

Seelbaugh v. Montgomery Cty. Court of Common Pleas, Domestic Relations Div., 2025‑Ohio‑5297, is best understood as a strong reaffirmation of existing Ohio doctrine rather than a radical doctrinal shift. Its key contributions are:

Procedural discipline in extraordinary writs. Courts will strictly enforce requirements regarding proper respondents (non‑sui‑juris courts cannot be sued) and compliance with local filing rules, even against pro se litigants.
Clear boundaries for prohibition. Prohibition remains a narrow, extraordinary remedy reserved for instances of clear jurisdictional overreach, not for revisiting routine domestic‑relations and CSEA actions subject to appeal or administrative review.
Rejection of sovereign‑citizen strategies. Attempts to evade domestic‑relations and child‑support jurisdiction via trusts, estates, or other artificial constructs are squarely rejected and deemed non‑cognizable as jurisdictional objections.
Due process is for appeals, not for prohibition. Allegations that the structure or incentives of Title IV‑D magistrates or CSEAs violate due process do not by themselves defeat jurisdiction; such claims must be raised via objections and appeals.
Adequate remedies matter. The Court reiterates, with particular clarity, that:
- The ability to file objections to a magistrate’s decision is an adequate remedy in the ordinary course of law; and
- Statutory rights to administrative and judicial review (as with CSEA defaults) likewise bar recourse to prohibition.

For practitioners, the decision serves as a guidepost: when representing parties in domestic‑relations and child‑support matters, efforts should focus on using the ordinary procedural tools—objections, hearings, and appeals—provided by the statutes and rules. For courts and agencies, it offers strong precedent to efficiently dismiss prohibition actions premised on sovereign‑citizen rhetoric, non‑jurisdictional due‑process complaints, or dissatisfaction with the outcomes of ordinary procedures.

In Ohio’s broader legal landscape, Seelbaugh strengthens the line between what is truly jurisdictional and what is a claimed procedural or constitutional error to be addressed through the normal channels of appellate review—ensuring that extraordinary writs remain, as intended, truly extraordinary.

Prohibition, Sovereign‑Citizen Trust Gambits, and Adequate Remedies in Ohio Child‑Support Enforcement: Commentary on Seelbaugh v. Montgomery Cty. Court of Common Pleas, Domestic Relations Div., 2025‑Ohio‑5297