In re B.H.

Citations

• 2026 Ohio 1213

Syllabus

The trial court's award of permanent custody of appellant's minor child to a public children services agency was not against the manifest weight of the evidence or based on legally insufficient evidence. The trial court had ample evidence before it to determine that the child was in the agency's temporary custody for over 12 months during a consecutive 22-month period, notwithstanding appellant's brief reunification with the child. Ample evidence in the record supported the trial court's finding that permanent custody to the public children services agency was in the child's best interests. Appellant's compliance with her case plan did not outweigh the child's need for permanency. The public children services agency made reasonable efforts to reunify the child with appellant before seeking permanent custody. Additionally, trial counsel was not ineffective for failing to call witnesses or present evidence during the permanent custody hearing because such decisions are within the realm of reasonable trial strategy. Judgment affirmed.