In re J.L.

Citations

• 2026 Ohio 1216

Syllabus

JUVENILE — CUSTODY — NONPARENT — MOOTNESS — EVIDENCE — ABANDONMENT — CIV.R. 60(B) — JUV.R. 13 — R.C. 2151.23(A)(2): A judgment granting legal custody to a nonparent under R.C. 2151.23(A)(2) supersedes an interim-custody order entered under Juv.R. 13(A) and renders any subsequent challenge to the interim-custody order moot. An interim-custody order entered under Juv.R. 13(A) does not bar subsequent litigation of a parent's suitability. The juvenile court did not abuse its discretion in awarding legal custody of father's daughter to appellee grandmother where the record supports that father abandoned his daughter by having no contact with her for at least an eight-year period because he wanted to avoid confrontation with mother. The juvenile court did not abuse its discretion when denying father's motion for relief from the legal-custody judgment under Civ.R. 60(B) without holding a hearing where father failed to allege operative facts warranting relief.