In re C.L.

Citations

• 2022 Ohio 3596

Syllabus

A due process violation occurs if a parent is absent from a dispositional hearing where the parent's faces the potential loss of significant parental rights, the parent learns only one business day before the hearing that the parent will not be able to attend, and the hearing could have been rescheduled without significant impact on the children. A trial court abuses its discretion by denying a motion for a continuance where the requested continuance was necessary to accord the movant due process.