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In re E.A.

Citations

  • 2019 Ohio 2964

Syllabus

Arguments as to abandonment and placement within reasonable time are moot where it is undisputed that the child was in the custody of the agency for at least 12 months of a consecutive 22-month period. The juvenile court need only make one of the five enumerated findings contained in R.C. 2151.414(B)(1). As to the best interest factors, the juvenile court did not err by granting permanent custody in favor of the children services agency where the parents had not seen the child in more than two years and failed in their case plan requirements.

Judges: Ringland

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