In re C Children

Citations

• 209 N.E.3d 819
• 2023 Ohio 588

Syllabus

CUSTODY – PARENTAL TERMINATION – COUNSEL – WAIVER. In a permanent custody case, the juvenile court erred in determining that legal custodian maternal grandmother waived her right to counsel, notwithstanding her firing of three attorneys, where the magistrate failed to communicate to her the dangers of proceeding without counsel. [But see DISSENT: The juvenile court did not abuse its discretion in denying grandmother's day-of-trial request for a continuance under R.C. 2151.352 where the record shows that grandmother obtained and fired three, separate appointed attorneys and subsequently failed to appear at the next three hearings, including the final pretrial hearing, and grandmother arrived late to the permanent-custody trial, which was already in progress, and requested a continuance to obtain private counsel.]