In re L.W.

Citations

• 2018 Ohio 2099

Syllabus

Juvenile court grant of permanent custody of children to children services agency was not against the manifest weight of the evidence and did not violate due process where there was competent credible evidence to support the court's determination that granting custody was in the best interest of the children and appellant did not challenge the court's determination that the children had been in the agency's custody for twelve or more months in a consecutive twenty-two-month period. Juvenile court did not commit plain error by failing to appoint separate counsel for one of the children where record reflected that child was of young age and had an intellectual disability, and evidence did not indicate that child expressed strong, consistent desire to return to parent's custody. Appellant failed to demonstrate ineffective assistance of trial counsel based on failure to object to in camera interview, introduction of psychologist's reports, or alleged hearsay testimony because appellant failed to establish a reasonable probability that result of proceeding would have been different if counsel had taken these actions.