In re S.N.L.

Citations

• 2022 Ohio 698

Syllabus

Permanent custody best interests of child determination CCDCFS R.C. 2151.414 clear and convincing evidence abuse of discretion manifest weight of the evidence. Judgment affirmed. When proceeding on a motion for permanent custody, the juvenile court must satisfy the two-prong test set forth in R. C. 2151.414 before it can terminate parental rights and grant permanent custody to the agency. The juvenile court must find by clear and convincing evidence that (1) at least one of the conditions set forth in R. C. 2151.414 (B)(1)(a) through (e) applies, and (2) it is in the best interest of the child to grant permanent custody to the agency. The evidence demonstrated that the child cannot be placed with Mother within a reasonable period of time Mother failed to demonstrate sufficient benefit from the substance abuse services establish a plan for sober living submit to the weekly drug screen requests made by CCDCFS secure appropriate housing and complete mental health treatment services. As a result, there is clear and convincing evidence in the record to support the juvenile court's determination that permanent custody be awarded to CCDCFS. Accordingly, the court's decision to grant permanent custody is not against the manifest weight of the evidence and the court did not abuse its discretion in determining that permanent custody of the child be awarded to CCDCFS.