In re J.H.

Citations

• 2021 Ohio 2922

Syllabus

CHILDREN – CUSTODY – PARENTAL TERMINATION – PLAIN ERROR – R.C. 2151.281 – EVIDENCE – HARMLESS ERROR – R.C. 2151.414(E) – R.C. 2151.353(A)(4): The juvenile court did not commit error, much less plain error, by failing to hold a competency hearing to determine father's competency where the juvenile court appointed a guardian ad litem as required by R.C. 2151.281(C). The juvenile court did not commit error, much less plain error, by denying father's request to represent himself where the request was untimely, the request was not a clear and unequivocal request, and father's guardian ad litem did not object or in any way take issue with the trial court's decision. The juvenile court did not commit error, much less plain error, by removing father from the courtroom for a portion of one witness's testimony where father was removed due to his own behavior and father was represented by his trial counsel and his guardian ad litem during his absence. The juvenile court did not err in admitting the testimony of a witness where the testimony did not constitute hearsay. The juvenile court did not commit plain error in admitting the testimony of a witness where the testimony was cumulative to properly admitted testimony. The juvenile court did not commit plain error in admitting hearsay testimony where the admission of the testimony did not seriously affect the basic fairness, integrity, or public reputation of the judicial process, thereby challenging the legitimacy of the underlying judicial process itself. The admission of a witness's hearsay testimony was harmless error where the record did not indicate, and father did not argue, that the trial court relied on the testimony when rendering its decision. An appellate court may disregard an assignment of error where \the party raising it fails to identify in the record the error on which the assignment of error is based.\ App.R. 12(A)(2). The juvenile court's admission of unobjected to testimony elicited by father's trial counse