In re D.R.

Citations

• 2025 Ohio 2839

Syllabus

The trial court abused its discretion in its handling of the permanent custody proceedings on remand leaving it unable to satisfy its obligation to engage in a complete analysis of whether granting permanent custody to Franklin County Children Services (\FCCS\) is in the child's best interest. Given the incompleteness of the record related to the child's and father's circumstances since the first trial in October 2021, and in light of the amount of time that has now passed since the first trial, the trial court could not–and did not–adequately consider and determine the child's best interest at the time of the remand proceedings. Because we are unable to discern, from this record, whether permanent custody remains in the child's best interest nearly four years after the trial court's initial decision granting permanent custody, we must reverse the judgment of the trial court and remand the matter to the trial court for further proceedings.