In re M.A.L.-C.

Citations

• 2022 Ohio 1845

Syllabus

Temporary custody neglect dependent kinship search R.C. 2151.4116 hearsay abuse of discretion clear and convincing evidence. The juvenile court did not abuse its discretion when awarding temporary custody to CCDCFS. The court's findings were sufficient to justify the adjudication of neglect pursuant to R.C. 2151.03(A)(2) and of dependency pursuant to R.C. 2151.04(C). In juvenile court proceedings, there must be strict adherence to the Rules of Evidence at the adjudicatory stage. Yet, any evidence that is material and relevant, including hearsay, opinion, and documentary evidence, is admissible at the dispositional stage. The erroneous admission of hearsay evidence is harmless if other evidence, apart from the erroneously admitted evidence, proves that which the challenged evidence was offered to prove. R.C. 2151.4116 promotes the placement of children with family members where possible. Here, the child was placed with maternal grandmother. Therefore, the statutory requirements were satisfied.