In re D.R.-S.

Citations

• 2025 Ohio 2873

Syllabus

Trial court did not err by proceeding with permanent custody hearing without mother present because mother's counsel had been notified of the hearing date as required by the procedural rules and there was no evidence that notice of the hearing date sent to mother by regular mail had been returned to the court. Trial court did not abuse its discretion by allowing children services agency to recall caseworker to give additional direct testimony after her testimony ended the prior day because the testimony given on recall was limited in scope to identifying orders related to prior custody actions and relevant criminal proceedings, and appellant's counsel was provided the opportunity to cross-examine the caseworker. Trial court's decision that a grant of permanent custody was in the child's best interest was not against the manifest weight of the evidence because although there was some evidence tending to establish mother complied with portions of her case plan, there was also evidence that mother failed to fulfill other portions of her case plan and did not remedy the conditions that caused the agency to seek custody of the child.