In re A.F.

Citations

• 2021 Ohio 4519

Syllabus

Permanent custody reasonable efforts legal custodian visitation foster home distance placement ineffective assistance legal custody best interest bond clear and convincing manifest weight R.C. 2151.414(B) R.C. 2151.414(D)(1). Affirmed award of permanent custody to children services agency. The juvenile court did not abuse its discretion in finding reasonable efforts were made in its permanent-custody decisions. The agency provided case-plan services and supportive-visitation services and although the children were placed in a foster home almost three hours away, the record showed the agency made extensive efforts to facilitate visitation with their mother and their former legal custodian. Mother failed to demonstrate that she received ineffective assistance of trial counsel with regard to trial counsel's decision not to pursue legal custody to an interested individual. The juvenile court's determination that an award of permanent custody is in the best interest of each child was supported by clear and convincing evidence in the record and was not against the manifest weight of the evidence. Although the children's former legal custodian completed case-plan services and was reunified with her biological children, the record reflected that the juvenile court considered and weighed all relevant best-interest factors under R.C. 2151.414(D)(1) and other relevant factors in deciding whether to award permanent custody.