E.A.K.M. v. M.A.M.

2025 - Ohio - 2946 (Aug. 21, 2025) (DeWine, J.; Kennedy, C.J., concurring in judgment only)

Holding. Finality is decided by category of order, and an interlocutory order to pay guardian ad litem fees in a pending divorce and custody case is not final under R.C. 2505.02(B)(2) (¶ 21-23, 26). Court of appeals’ judgment vacated. Decided before October 1, 2025.

Takeaways. Because review of an interim fee order generally waits for the final

judgment, consider paying under protest and asking for reallocation or a refund in the decree.