In re C.D.

Citations

• 2025 Ohio 1264

Syllabus

Termination of parental rights; permanent custody; dispositional hearing; R.C. 2151.35; 90 days after filing of complaint; dismiss with prejudice; plain error; hearing must commence; ineffective assistance of counsel; deficiency prejudiced defense; failure to seek writ of procedendo; R.C. 2151.414; statutory timeframe for resolution of motion for permanent custody. The trial court did not err in declining to dismiss the case because it did not violate the statutory timeframe. The dispositional hearing was commenced within 90 days of the refiled complaint. Further, Mother's counsel did not demonstrate that her counsel was ineffective for failing to seek a writ of procedendo with regard to the motion for permanent custody.