In re A.D.

Citations

• 2022 Ohio 736

Syllabus

The juvenile court did not commit error, plain or otherwise, in granting permanent custody of appellant's twin daughters to a children services agency under the two-part test set forth under R.C. 2151.414(B)(1) where granting permanent custody was in the children's best interest given that appellant had not been economically stable for the life of the case, appellant was basically homeless for much of the case, and appellant continued to struggle with mental health and substance abuse issues for which appellant did not believe she needed treatment. However, as it relates to appellant's third child, a boy, the juvenile court committed plain error by not applying the appropriate two-pronged test set forth under R.C. 2151.353(A)(4) to the children service agency's request for permanent custody, thereby requiring the matter be remanded to the juvenile court with instructions to apply the correct statutory framework to the children services agency's permanent custody request.