In re H.R.H.

Citations

• 2020 Ohio 3160

Syllabus

CHILDREN – CUSTODY – PARENTAL TERMINATION – JUV.R. 40(C)(2)(c) – R.C. 2151.414 – BEST INTEREST: The magistrate did not exceed her authority under Juv.R. 40(C)(2)(c) where she did not act as an advocate: the magistrate did not examine the witness in a biased manner, the magistrate asked questions directed only toward the clarification and foundation of the witness's testimony, and when mother's counsel raised an objection, the magistrate either overruled the objection or rephrased her question. The juvenile court's determination that the child cannot be placed with mother within a reasonable time or should not be placed with mother was supported by clear-and-convincing evidence, including that mother failed to prove that she could provide secure placement and adequate care for the child, and failed to remedy her severe chemical dependency and mental-health problems. The juvenile court's determination that granting permanent custody to Hamilton County Job and Family Services was in the best interest of the child was supported by clear-and-convincing evidence, including evidence of the absence of a significant bond between mother and the child, who had lived his entire life in agency custody, and the child's need for a stable and secure placement.