In re L.C.

Citations

• 2022 Ohio 1592

Syllabus

Permanent custody necessity of expert testimony for parent's mental health ineffective assistance of counsel admissibility of electronic print media. Our review of the record reflects the trial court engaged in the required analysis and its findings under R.C. 2151.414(B)(1) and (E) are supported by clear and convincing evidence contained in the record. No expert testimony is required for the finding regarding appellant parent's mental health. Counsel's performance was not defective for not objecting to the admission of electronic print media that were properly authenticated by witness testimony.