In re K.D.

Citations

• 2024 Ohio 5582

Syllabus

PARENTAL TERMINATION — BEST INTEREST — SECURE LEGAL PLACEMENT — EVIDENCE — SUFFICIENCY — MANIFEST WEIGHT: The juvenile court's finding that an award of permanent custody of appellant-mother's child to a child-services agency was in appellant-child's best interest was supported by sufficient evidence because medical records and caseworker testimony established that appellant-mother failed to demonstrate that she was able to care for appellant-child's diabetes. The juvenile court's finding that terminating appellant-mother's custody of appellant-child, and awarding permanent custody of appellant-child to a child-services agency, was in appellant-child's best interest was not against the manifest weight of the evidence despite appellant-mother's testimony describing the care necessary for appellant-child's diabetes because medical records and caseworker testimony established that appellant-mother failed to intervene when, in appellant-mother's presence, appellant-child ate food and miscalculated carbohydrates on one occasion and failed to administer an insulin injection on another occasion, and appellant-child's medical records include a nurse educator's conclusion that appellant-mother could not safely manage appellant-child's diabetes and the nurse educator identified multiple areas of concern regarding appellant-mother's understanding of diabetes care. [See CONCURRENCE: Ohio's parental-termination laws harm older children, who are less likely to find permanent family arrangements and more likely to suffer stigma and collateral consequences, by removing them from a parent solely on the basis that the parent cannot provide adequate medical care.]