Background
Shonte Henderson, a registered nurse seeking to own or operate a youth residential facility, challenged Cuyahoga County Division of Children and Family Services dispositions recorded in Ohio’s child-welfare information system. The agency’s July 8, 2025 letter upheld certain neglect dispositions, which the agency later corrected the record to state included both indicated and substantiated dispositions, while changing two others.
Henderson filed an administrative appeal in the common pleas court under R.C. 2506.01. She alleged that the dispositions harmed her licensing and employment prospects and that the agency denied her adequate notice, access to evidence, witnesses, and a meaningful opportunity to challenge the allegations. The common pleas court dismissed for lack of subject-matter jurisdiction.
The Court’s Holding
The Eighth District affirmed. On reconsideration, it vacated its earlier opinion because that decision had relied partly on the mistaken premise that the July 2025 letter upheld only an indicated disposition. But the correction did not change the result.
Under the Ohio Supreme Court’s decision in Kyser, a public children-services agency’s abuse or neglect disposition is not appealable under R.C. 2506.01 because the disposition itself does not determine a person’s rights, duties, privileges, benefits, or legal relationships. That rule applies even to substantiated dispositions. Henderson’s evidence did not establish that the July 2025 letter itself conclusively determined her licensing or employment rights. Because the trial court lacked jurisdiction, neither it nor the appellate court could reach her due-process and sufficiency-of-findings claims.
Key Takeaways
- A children-services agency’s indicated or substantiated neglect disposition is not, by itself, a final order appealable under R.C. 2506.01.
- Potential employment or licensing consequences do not establish R.C. 2506.01 jurisdiction unless the challenged agency decision itself conclusively determines those rights.
- When a court lacks subject-matter jurisdiction over an administrative appeal, it cannot decide constitutional or substantive challenges raised within that appeal.
Why It Matters
The decision applies Kyser to confirm that the categorization of a child-neglect disposition as indicated or substantiated does not make it appealable under R.C. 2506.01. Practitioners challenging the effects of child-welfare findings must identify a proper jurisdictional vehicle rather than rely on an R.C. 2506.01 appeal from the disposition letter alone.