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In re S.L.

Citations

  • 2019 Ohio 815

Syllabus

Where minor child had been adjudicated dependent and a dispositional award of legal custody to non-relatives had been entered, trial court erred when it did not appoint counsel to indigent father on his motions for a communication order and to change parenting time, which were, in effect, motions to modify the trial court's dispositional order under R.C. 2151.353(F)(2).

Judges: Mayle

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