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Mohamed v. Adam

2026-09-01

Summary

Holding. The appellate court overruled all eight assignments of error and affirmed the trial court's September 18, 2025 judgment denying and dismissing Mr. Adam's motions, finding that he had forfeited his challenges through waiver and prior failure to timely object, and that his arguments lacked legal and factual merit.

Ali O. Adam appealed the trial court's September 2025 order denying and dismissing multiple motions he filed challenging jurisdiction and enforcement of a child support obligation. The underlying child support order originated in Vermont in 2017 for $400 per month and was registered in Ohio in 2018. When Mr. Adam failed to pay, the state child support agency filed a contempt motion in 2024, resulting in a judgment converting his obligation to a lump sum and imposing a driver's license suspension. Mr. Adam subsequently filed numerous motions arguing the court lacked jurisdiction and that his constitutional rights were violated, all of which the trial court denied or dismissed.

The appellate court found that Mr. Adam had forfeited his arguments by failing to timely object to earlier rulings and by waiving his jurisdictional objections through his own earlier participation in the case. The court noted that Mr. Adam had filed a modification motion in 2018, received proper notice of the 2018 registration of the Vermont order, and voluntarily participated in 2024 contempt proceedings before raising jurisdiction challenges. The court concluded that Mr. Adam's later motions were merely attempts to relitigate points already decided and that his remaining arguments lacked legal merit and factual support.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Waiver and forfeiture of jurisdictional challenges through failure to timely object
  • Whether Ohio courts properly acquired jurisdiction over a Vermont-registered child support order
  • Whether the trial court could deny reconsideration motions after denying an earlier motion to dismiss
  • Whether administrative driver's license suspensions complied with due process notice requirements

Procedural posture

Mr. Adam appealed the Franklin County trial court's September 18, 2025 order denying and dismissing multiple motions he filed during 2024 and 2025 challenging jurisdiction and enforcement of a 2018-registered Vermont child support order.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion

majority opinion

[Cite as Mohamed v. Adam, 2026-Ohio-3410.]

IN THE COURT OF APPEALS OF OHIO

TENTH APPELLATE DISTRICT

Fatuma Mohamed, :

Plaintiff-Appellee, :

No. 25AP-818

v. : (C.P.C. No. 18JU-7512)

Ali O. Adam, : (REGULAR CALENDAR)

Defendant-Appellant. :

D E C I S I O N

Rendered on September 1, 2026

On brief: Ali O. Adam, pro se. Argued: Ali O. Adam.

APPEAL from the Franklin County Court of Common Pleas,

Division of Domestic Relations and Juvenile Branch

BEATTY BLUNT, J.

{¶ 1} Defendant-appellant, Ali O. Adam, appeals the September 18, 2025 judgment of the Franklin County Court of Common Pleas, Division of Domestic Relations and Juvenile Branch. That order denied and dismissed several motions filed by Mr. Adam during 2024 and 2025. Plaintiff-appellee, Fatuma Mohamed, did not appear below and has not filed a brief in this court.

{¶ 2} The underlying case stems from a 2017 child support order entered in the state of Vermont and registered in Ohio in 2018—that order was agreed to by Mr. Adam and required him to pay $400 per month for the support of his two minor children. Mr. Adam resides in Ohio and has for several years.

{¶ 3} Mr. Adam initially filed a motion to modify his child support obligation on October 23, 2018, but he withdrew that motion without prejudice on May 20, 2019. The case then lay dormant for several years, but on March 15, 2024, Ms. Mohamed and the Franklin County Child Support Enforcement Agency (“FCSEA”) filed a motion to find Mr. Adam in contempt for nonpayment of support, and to liquidate his arrearage to a lumpNo. 25AP-818 2

sum amount of $16,705.49. The FCSEA also imposed a new administrative driver’s license suspension onto Mr. Adam for nonpayment.

{¶ 4} After several unsuccessful attempts at service, Mr. Adam signed and filed an entry acknowledging service of the motion for contempt on May 1, 2024. On May 22, 2024, he filed a motion to dismiss the motion for lack of subject-matter jurisdiction, based on the argument that “child support is a private organization.” (May 22, 2024 Petition/Mot. to Dismiss for Lack of Subject Matter Jurisdiction at 2.) Following a hearing, the magistrate dismissed Mr. Adam’s motion to reinstate his driver’s license as moot, sustained the motion for contempt, imposed a sentence of 30 days of suspended jail time upon Mr. Adam, and converted his child support amount to a lump sum of $15,599.02, to be paid at a rate of $80 per month, plus poundage, until fully liquidated. Mr. Adam then filed a number of exhibits purporting to allege violations of fundamental rights by Ohio courts regarding the collection of fines without first establishing the ability to pay, and another set of exhibits captioned “Affidavit’s Opposition to Contempt or Sanctions” arguing that his rights were violated because he was sentenced to a (suspended) sentence for nonpayment and that he “reserved his right to file lawsuit for $10 million.” (June 20, 2024 Ex. A at 4.) On June 27, 2024, he filed a pleading arguing that because he was an independent contractor, he was not required to participate in the federal child support program, contending that “Title IVD is a Private Organization and Therefore it is Unconstitutional.” Id. at 6.

{¶ 5} On September 23, 2024, the trial court judge issued an order denying Mr. Adam’s motion to dismiss for lack of subject-matter jurisdiction, observing that Mr. Adam had not filed any objection to the registration of the foreign child support order within the statutory time frames, and that it “was not until a Motion for Contempt was filed against him did [Mr. Adam] file to challenge [the trial] Court’s jurisdiction.” (Sept. 23, 2024 Decision Den. Petition/Mot. to Dismiss for Lack of Subject Matter Jurisdiction at 6.) Mr. Adam did not appeal this decision, but he filed a “Demand [for] an Administrative Hearing” regarding his driver’s license suspension, and an “Affidavit in Objection” to the trial court’s order, again arguing that the trial court did not have jurisdiction over him or the child support matter because he was an independent contractor not subject to child support enforcement. The court subsequently denied this “Affidavit in Objection,” observing that Mr. Adam “did not file an appeal and instead filed the subject Objection” No. 25AP-818 3

despite the fact that “[a]t the hearing, [the trial] Court again informed [Mr. Adam] of his right to appeal,” and because the “appropriate recourse for [Mr. Adam] is an appeal, not an Objection to the Judge’s Decision.” (Feb. 12, 2025 Entry Dismissing Def.’s Obj. to Judge’s Decision at 1.) Similarly, on February 13, 2026, the magistrate denied Mr. Adam’s “Demand [for] an Administrative Hearing,” observing that, as a result of R.C. 3123.60, it “cannot order the BMV or any other state agency to grant a state administrative hearing regarding [Mr. Adam]’s driver’s license suspension,” that the domestic relations court was “not the proper forum” for him to claim damages from “the Governor, the Attorney General and the Ohio Registrar,” and that the court “has no authority to order the State to grant [Mr. Adam] a jury hearing on the suspension of his license.” (Feb. 13, 2025 Jgmt. Entry & Mag.’s Decision at 3.)

{¶ 6} On January 30, 2025, Mr. Adam filed a motion seeking reconsideration of the trial court’s September 23, 2024 decision denying his motion to dismiss. He then filed a motion for reconsideration of the trial court’s September 23, 2024 decision and reconsideration of the magistrate’s decision on his demand for an administrative hearing, and he filed an objection to the magistrate’s decision denying his request for an administrative hearing on March 27, 2025. On April 29, 2025, he then attempted to file a motion for a delayed appeal of the judgment entries filed on September 23, 2024 and February 12, 2025, but this court dismissed the motion, noting that he was not entitled to a delayed appeal pursuant to App.R. 5(A). (May 1, 2025 Journal Entry of Dismissal, 10th Dist. No. 25AP-377.)

{¶ 7} On August 12, 2025, Mr. Adam filed a “Combined Motion to Vacate Judgment, Rebut Presumed Jurisdiction, and Dismiss with Prejudice for Lack of Jurisdiction, Extrinsic Fraud, and Due Process Violations.” Several days later, he filed a similar “Motion to Vacate License Suspensions, Dismiss Enforcement Actions with Prejudice, and for Sanctions.” On August 20, 2025, he filed a “Master Motion to Dismiss for Fraud, Lack of Jurisdiction, Failure of Service, Res Judicata, and to Vacate Enforcement Actions.” On August 22, 2025, he filed a “Supplement to Motion to Vacate License Suspensions, Dismiss Enforcement Actions with Extreme Prejudice, and for Sanctions.” And on August 25, 2025, he filed a “Notice of Lack of Subject Matter Jurisdiction.” The No. 25AP-818 4

trial court held a hearing on August 28, 2025 on all of these motions, and on September 18, 2025, it denied or dismissed them all. (Sept. 18, 2025 Decision.)

{¶ 8} Mr. Adam filed an appeal of the trial court’s September 18, 2025 decision on October 28, 2025, and now sets forth eight assignments of error:

1. The trial court erred by contradicting its own jurisdictional

dismissal of September 23, 2024.

2. The trial court violated due process by upholding

unconstitutional license suspensions in 2021 and 2023.

3. The trial court erred by allowing post-dismissal enforcement

after October 2, 2024.

4. The trial court misstated facts and ignored material

evidence.

5. The trial court failed to consider sworn affidavits of nonservice, hardship, and fraud.

6. The trial court violated Appellant’s constitutional rights

under the Fifth and Fourteenth Amendments.

7. The trial court denied equal access to justice by dismissing

the Master Motion without review.

8. The trial court proceeded without valid service, violating

Maryhew v. Yova and due process.

{¶ 9} However, we must overrule all of Mr. Adam’s assignments of error, as he has forfeited our consideration of his arguments several times over. Mr. Adam initially waived his objection to Ohio’s exercise of jurisdiction over the case in 2018 by filing a motion to modify, even though he withdrew it. Mr. Adam also failed to file a timely objection to the magistrate’s initial June 10, 2024 decision to grant the motion for contempt and reduce his nonpayment amounts, and the magistrate’s decision was accordingly adopted by the trial court on that same date. Mr. Adam’s motion to dismiss for lack of subject-matter jurisdiction was denied by the trial court on September 23, 2024, and he did not appeal, rendering that judgment final and giving it res judicata effect. (Sept. 23, 2024 Decision Den. Petition/Mot. to Dismiss for Lack of Subject Matter Jurisdiction.)

{¶ 10} Mr. Adam’s motions that led to this appeal are all just attempts to revive and reargue the same points he lost in those two rulings. And even assuming he has not forfeited those points, his assignments of error wholly lack merit. In his first assignment of error, he essentially argues that because the trial court denied his motion to dismiss for lack No. 25AP-818 5

of subject-matter jurisdiction in September 2024, the court had no authority to deny his motions for reconsideration of that decision in September 2025. This is not really a legal argument, and it misunderstands the nature of the trial court’s authority in this case—the trial court correctly concluded that it possessed subject-matter jurisdiction based on the 2018 registration of the foreign order:

[T]his case was created in Vermont in 2017. Defendant did not

object to that order, nor did he seek to vacate it. It was then

transferred to Franklin County, Ohio, on June 20, 2018.

Defendant did not file any objections to the registration of the

foreign order within the statutory timeframes, despite

receiving notice of such by certified mail. Defendant attempted

to modify his child support by filing a Motion for Modification

October 23, 2018, through this Court. He ultimately withdrew

his request on May 20, 2019. On May 1, 2024, Defendant

voluntarily signed a waiver of service of the Motion for

Contempt. Moreover, was not until a Motion for Contempt was

filed against him did Defendant file to challenge this Court’s

jurisdiction. Defendant even participated in the hearing before

the Magistrate on June 4, 2024, regarding the Motion for

Contempt. Since 2018, Defendant has continuously acquiesced

to and utilized the Franklin County Court of Common Pleas

Court, Domestic Relations Division and Juvenile Branch’s

jurisdiction in this case. It was only when there were potential

penalties levied against him that Defendant raised the issue of

subject matter jurisdiction. The Court finds Defendant’s

arguments for lack of jurisdiction to be without merit.

Id. at 5-6, citing R.C. 3105.011, R.C. 2301.03, and R.C. 2152.23; see also Sept. 18, 2025 Decision at 5. We can find no fault in the trial court’s analysis, and therefore we overrule Mr. Adam’s first assignment of error.

{¶ 11} Mr. Adam’s second and third assignments of error assert issues with the imposition and enforcement of an administrative driving license suspension during the period of 2021 through 2024 and specifically argue that he was entitled to court notice of the suspensions and also that the trial court “dismissed” the case in 2024. Both of these issues have been raised far beyond the deadline for such challenges, were improperly presented to the trial court, and lack factual merit—even assuming his challenges were timely and proper in the trial court, Mr. Adam failed to show that he did not receive sufficient notice of his license suspensions. And the trial court’s September 23, 2024 order No. 25AP-818 6

did not dismiss the case, it denied his motion to dismiss. (Sept. 23, 2024 Decision Den. Petition/Mot. to Dismiss for Lack of Subject Matter Jurisdiction.)

{¶ 12} Mr. Adam’s remaining assignments of error are without any support in the law or the record—he was properly notified of the proceedings and voluntarily appeared before courts at the time of the initial 2017 Vermont child support order, for the 2018 Ohio registration of the order, for his own 2018 motion to modify his support obligation, and the 2024 contempt proceedings. The trial court’s proceedings and conclusions here are wellsupported by the decision issued on September 18, 2025, and Mr. Adam has not shown unfair prejudice as a result of that decision. (Sept. 18, 2025 Decision.)

{¶ 13} For all the foregoing reasons, we overrule all eight of Mr. Adam’s assignments of error and affirm the judgment of the Franklin County Court of Common Pleas, Division of Domestic Relations and Juvenile Branch.

Judgment affirmed.

MENTEL and EDELSTEIN, JJ., concur.