In re J.H.

Citations

• 2019 Ohio 696

Syllabus

Manifest weight best interest of the children restrictive visitation abuse of discretion removal of guardian ad litem. Under the guidelines of R.C. 2151.281 and Juv.R. 4, Mother was not entitled to a GAL, and the outcome of the proceeding was not based solely on GAL representation for Mother. Mother participated during the hearing, competently testifying, presenting her concerns, and responding to the custodian's testimony. It was properly determined that it was not in the best interest of the children to change custody. It was an abuse of discretion for the trial court to limit Mother's visitation with one child so that she had no visitation at all. It was an abuse of discretion for the trial court to not allow the two children to visit and bond with one another.