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In re A.V.

Citations

  • 2022 Ohio 1061

Syllabus

Legal custody Fifth Amendment self-incrimination abuse of discretion invited error. The trial court did not abuse its discretion when it declined to allow Mother's counsel to call Mother as a witness at the conclusion of the hearing when Mother had multiple prior opportunities to testify and declined. While the Fifth Amendment does not allow an individual to completely refuse to testify in juvenile court proceedings, the invited-error doctrine applies to preclude Mother from taking advantage of this error on appeal.

Judges: Kilbane

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