In re J/B Children

Citations

• 2020 Ohio 1085

Syllabus

CHILDREN – CUSTODY – PARENTAL TERMINATION – CONTINUANCE – RIGHT TO COUNSEL – WAIVER – R.C. 2151.414 – BEST INTEREST: The juvenile court did not abuse its discretion in denying mother's motion to continue the permanent-custody hearing where mother gave no indication of when she would be ready to proceed, mother had engaged in previous dilatory tactics, and the state had witnesses present at the hearing. The juvenile court did not deprive mother of the right to counsel in a parental-termination case where the record reflects mother's valid express waiver of the right to counsel: mother stated her desire to proceed pro se, had been fully informed of the consequences of proceeding pro se, and had rejected appointed counsel. The juvenile court did not err in awarding permanent custody of the child to the Hamilton County Department of Job and Family Services where the record demonstrated that the juvenile court considered the appropriate factors and the evidence supported the court's decision, including evidence of the absence of a significant bond between mother and the child, mother's lack of insight into the child's mental-health issues, and the child's need for a stable and secure placement.