In re De.R.
Citations
- 2024 Ohio 1183
Syllabus
JUVENILE – PLAIN ERROR – EVIDENCE – LAY TESTIMONY – REASONABLE EFFORTS – PERMANENT CUSTODY – SUFFICIENCY – MANIFEST WEIGHT – BEST INTEREST – R.C. 2151.413: The juvenile court's admission of expert testimony by a lay witness was not plain error when the testimony largely overlapped with other admitted evidence. The juvenile court's removal of Mother's youngest child was not plain error when Mother stipulated to interim custody, and there is no evidence that her stipulation was not knowing and voluntary. The magistrate's finding that the agency made reasonable efforts toward reunification was not plain error when the agency provided Mother with services, and Mother had difficulty engaging with services due to two periods of incarceration. The juvenile court properly granted permanent custody to the agency when clear and convincing evidence supported its finding that a grant of permanent custody to the Hamilton County Department of Job and Family Services was in the best interest of the children.
How courts have described this case
Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.
- noting that court was unaware of any precedent holding that failure to apply merger doctrine would support habeas relief under due-process theory
- holding a life sentence is not grossly disproportionate for the murder of a four-month old child with malice aforethought
- rejecting the defendant's due process challenge to her conviction of felony murder based upon child endangerment because the argument lacked a constitutional basis, depending instead upon the merger doctrine
Source: CourtListener parenthetical corpus (CC0).
Judges: Bergeron
Read full opinion on CourtListenerSourced from CourtListener / Free Law Project (CC0).
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