In re B.H.

Citations

• 2023 Ohio 3491

Syllabus

CHILDREN – PERMANENT CUSTODY – PARENTAL TERMINATION – RIGHT TO COUNSEL – R.C. 2151.352 – JUV.R. 4(A): The trial court erred and deprived mother of her right to counsel when, in the absence of both mother and mother's counsel, it proceeded as uncontested at a permanent custody hearing and rendered a decision permanently terminating mother's parental rights despite failing to reappoint mother's previously appointed counsel in refiled case, knowing mother intended to contest abuse allegation, and without first determining, on the record, whether mother had voluntarily, knowingly, and intelligently waived her right to counsel. Judgment reversed and cause remanded with instructions.