In re E.J.

Citations

• 2024 Ohio 2421

Syllabus

PARENTAL TERMINATION — MAGISTRATE — OBJECTIONS —JUV.R. 40 — INDEPENDENT REVIEW — BURDEN OF PROOF — CLEAR AND CONVINCING EVIDENCE: The juvenile court failed to independently review the record following mother's objections to the magistrate's decision terminating her parental rights where the juvenile court's judgment repeatedly referenced an appellate standard of review and held that the magistrate had not abused his discretion. The juvenile court erred by shifting the burden of proof to mother in a parental-termination case where the juvenile court adopted without modification the magistrate's finding that mother had failed to present clear and convincing evidence of her present mental-health status.