In re R.W.H.

Citations

• 2021 Ohio 4024

Syllabus

The trial court did not abuse its discretion in granting a children services agency permanent custody of a four-year-old child, as the trial court's findings under R.C. 2151.414(B)(1) and R.C. 2151.414(D)(1) were supported by clear and convincing evidence and were not against the manifest weight of the evidence. Father's multiple ineffective assistance of counsel claims lack merit and are also waived for appeal since Father waived his right to counsel at the permanent custody hearing and represented himself at the hearing. Father's claim that his constitutional rights to free speech and due process were violated also lacks merit. Judgment affirmed.