In re N.J.

Citations

• 2017 Ohio 7466

Syllabus

The juvenile court erred in adjudicating the children as dependent under R.C. 2151.04(D) where on the day the dependency complaints were filed, there was no prior adjudication that a sibling or other child residing in the household was an abused, neglected, or dependent child. The juvenile court did not err in adjudicating all three children as dependent under R.C. 2151.04(C) where father's physical abuse of the middle child and father's propensity to administer excessive discipline to the children formed part of the children's condition and environment. The juvenile court erred in adjudicating two of the children as abused under R.C. 2151.031(B) where the state failed to prove by clear and convincing evidence that the children were subjected to excessive corporal punishment, exhibited any signs of physical abuse, or were at risk for or suffered from any mental harm as a result of their father's disciplinary methods.