Ohio Supreme Court

Z.J. v. R.M.

December 23, 20252025 Ohio 5662

Summary

The court held that a petitioner seeking a civil stalking protection order need not prove that the respondent caused actual mental distress. Under the menacing-by-stalking statute, it is sufficient to show that the respondent's pattern of conduct knowingly caused the petitioner to believe that the respondent would cause mental distress. The court therefore affirmed the appellate judgment upholding the protection order.