In re R.H.

Citations

• 2024 Ohio 5009

Syllabus

Permanent custody; continuance; Juv.R. 23; Juv.Loc.R. 35; reasonable efforts; R.C. 2151.419(A). Juvenile court did not abuse its discretion in denying mother's oral motion for continuance at the permanent custody hearing, where mother requested a continuance to allow the agency to evaluate a family friend as a possible placement for the child. Mother did not comply with Juv.Loc.R. 35 and did not show that a continuance was \imperative to secure fair treatment for the parties\ as required under Juv.R. 23. No one filed a motion for legal custody and no one appeared at the permanent custody hearing to testify that they were willing and able to be a caregiver or legal custodian for the child. Mother did not show that the juvenile court failed to comply with its obligations under R.C. 2151.419(A). Where the juvenile court made reasonable-efforts findings before placing child in the permanent custody of the agency, it was not required to do so again in its judgment entry granting the agency's motion for permanent custody. Although it was not required to make such findings on the agency's motion for permanent custody, the juvenile court's reasonable-efforts findings were supported by clear and convincing evidence and were not against the manifest weight of the evidence. The record reflected that the agency developed a reasonable case plan and worked with mother for more one-and-one-half years, offering numerous referrals and services to mother, in an attempt to reunite her with her daughter. Mother, however, consistently failed to follow through with agency referrals, missing appointments, failing to comply with program requirements and ignoring recommendations for services.