In re B.M.H.

Citations

• 2025 Ohio 5180

Syllabus

JUVENILE - termination of parental rights; termination of father's rights; two children; case-plan goals; dual diagnostic assessment; updated; underemployment; hearings prior to agency filing for permanent custody; magistrate found agency made reasonable efforts to avoid continued removal; not case-plan compliant; manifest weight of the evidence; statutory requirement of reasonable efforts does not apply to permanent custody proceedings; other requirement may require demonstration of reasonable efforts toward family reunification; no challenge to agency's reasonable efforts; best interest of children; substance abuse; intoxication at visits; hostility toward caseworkers; guardian ad litem; recommendation; permanent custody to agency; ineffective assistance of counsel; counsel broached treatment issue; no updated assessment records; no ineffective assistance of counsel.