In re E.Z.-S.

Citations

• 2019 Ohio 1177

Syllabus

In a dispositional proceeding for a dependent child, trial court's failure to appoint a guardian ad litem under R.C. 2151.281(B)(2)(b) does not amount to plain error in absence of any evidence that a conflict of interest existed between child and father and/or that appointment would have affected the outcome. No abuse of discretion found where record supported trial court's conclusion that child's best interests would be served by change of custody from Mother to Father.