In re D.E.

Citations

• 2025 Ohio 654

Syllabus

Permanent custody; neglected; dependent; substance abuse; R.C. 2151.353(A); R.C. 2151.414(E); R.C. 2151.414(E)(11); R.C. 2151.414(D)(1); legal custody; reversible error; plain error; ineffective assistance; cumulative error. Affirmed juvenile court's decision granting permanent custody of the child to the children services agency and terminating mother's parental rights. The juvenile court's decision was supported by sufficient evidence and was not against the manifest weight of the evidence. The court engaged in the proper analysis and made the requisite determinations pursuant to R.C. 2151.353(A)(4) and in accordance with R.C. 2151.414(E) and 2151.414(D)(1) and did not err in denying legal custody to a proposed legal custodian. Though many challenges were raised, no reversible error occurred. Mother failed to demonstrate that the juvenile court committed plain error or that her counsel was ineffective. The cumulative-error doctrine was inapplicable.