Weaver v. Highberger

A trial court's termination of continuing jurisdiction in a habeas case is reviewed under an abuse of discretion standard.

Plaintiff appealed a judgment that ended the trial court’s continuing jurisdiction in his case, where he had secured habeas corpus relief due to Defendant’s failure to provide medical care. He raised three points of error: (1) the trial court’s denial of his motion for a fourth emergency hearing, (2) its refusal to reconsider its decision that the defendants had complied with the judgment, and (3) its termination of continuing jurisdiction. The court stated it had “not yet directly addressed [its] standard of review when evaluating a trial court's termination of continuing jurisdiction in a habeas corpus case," but considered the nature of the issues and concluded that "the most appropriate standard of review is for abuse of discretion.” The Court found that postponing the hearing on the fourth emergency motion was not an abuse of discretion, reasoning that it was rescheduled for valid reasons. The Court also found that the trial court did not err in denying the motion for reconsideration, as evidence supported that Defendants complied with the medical orders in the habeas judgment. Finally, the Court found that the decision to terminate continuing jurisdiction was not an abuse of discretion because there was sufficient evidence of the defendant's compliance, and the trial court had the discretion to make this ruling. The Court held that the trial court did not abuse its discretion in making any of the rulings. Affirmed.