In re M. Children

Citations

• 2025 Ohio 4744

Syllabus

PERMANENT CUSTODY – REASONABLE EFFORTS – BEST INTERESTS – MANIFEST WEIGHT: The juvenile court did not have to determine whether the child-services agency made reasonable efforts to reunify the family when deciding a motion for permanent custody filed under R.C. 2151.413 where a reasonable-efforts finding was made at earlier stages of the proceedings. The juvenile court's decision to grant the child-services agency permanent custody of the children based on mother's inability to provide a legally secure permanent placement to the children was not contrary to the manifest weight of the evidence where the evidence showed that mother continued to test positive for methamphetamine months before the custody hearing and had not distanced herself from her abusive relationship with father. [See CONCURRENCE: Given that permanent custody is the family law equivalent of the death penalty, and given that \behavioral change\ is a vague term with no legal meaning, greater precision is required in distinguishing cannot-or-should-not-place cases, in which the juvenile court can consider whether a parent remedied the conditions that led a child to be removed from the home, from 12-in-22 cases, in which the juvenile court considers the broader question of whether a parent can provide a legally secure placement for the child.]