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.