· 5/23/2024

In re A.I.

Citations

  • 2024 Ohio 1992

Syllabus

Permanent custody child cannot be placed with either parent within a reasonable time or should not be placed with the parents failure to remedy lack of commitment abandonment best interest determination clear and convincing evidence manifest weight of the evidence extension of temporary custody termination of custody when child reaches age of majority. Judgment affirmed. The juvenile court's judgment granting permanent custody of the child clearly and convincingly was supported by the weight of the evidence. Several of the provisions under R.C. 2151.414(E) applied and, thus, the trial court was required to find that the child cannot be placed with Mother within a reasonable time or should not be placed with Mother. Further, the juvenile court's best interest finding was supported by clear and convincing evidence. Because Mother had not made significant progress on her case plan, a first extension of temporary custody could not have been ordered and would not have been in the best interest of the child. The juvenile court lost jurisdiction over Mother when she turned 18 years old and none of the very limited exceptions under R.C. 2151.353(F)(1) applied to allow it to continue jurisdiction over her.

Judges: Ryan

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