In re E.T.J.

Citations

• 2026 Ohio 977

Syllabus

In a situation where a child has previously been adjudicated dependent and legal custody has been granted to a non-parent, the juvenile court did not commit plain error or otherwise abuse its discretion in denying the parents' motions for visitation. The record demonstrated the court considered the best interest factors set forth in R.C. 3109.051(D) and the totality of the circumstances demonstrated the mother's and father's progress with sobriety and stability was somewhat recent and occurred only while subject to court supervision and sanctions. The juvenile court also did not commit plain error or otherwise abuse its discretion by waiting more than a year to rule on the parents' motions for visitation where the delay did not prejudice the parents and was caused by service issues, attempts at mediation, and continuance requests that were acquiesced to by the parents.