In re T.F.

Citations

• 2025 Ohio 5051

Syllabus

Manifest weight; sufficiency; best interest; clear and convincing; reasonable time; failure to remedy; lack of commitment; abandonment; R.C. 2151.414(B)(1); R.C. 2151.414(D)(1)(a)-(e); R.C. 2151.414(E)(1); R.C. 2151.414(E)(4); R.C. 2151.414(E)(10); R.C. 2151.415(D); R.C. 2151.415(A); R.C. 2151.353(G); R.C. 2151.412(H)(2); R.C. 2151.412(F)(2). Judgment affirmed. Permanent custody to the Cuyahoga County Division of Children and Family Services (\CCDCFS\) was supported by clear and convincing evidence. Mother continuously failed to remedy substance abuse, mental-health, housing, and anger-management issues. She had inconsistent visitation with the children, which did not progress beyond supervised visits. Mother missed 39 drug screens and had no prospective sobriety date. Her visits with the children often included 30- to 45-minute phone distractions. One child became inconsolable when mother no-showed. Evidence also supported the juvenile court's finding that the children's father had abandoned them. These findings supported the conclusion that the children could not or should not be placed with either parent within a reasonable time. The statutory best-interest factors supported custody to CCDCFS, including, but not limited to, the guardian ad litem's recommendation, the children's custodial history since December 2023, and their need for a legally secure placement. Mother's manifest-weight and sufficiency challenges failed because competent, credible evidence established each statutory element. A finding that a judgment is supported by the manifest weight of the evidence necessarily includes a finding that sufficient evidence supports the judgment. We reject mother's argument that CCDCFS moved too quickly or was required to secure placement with a relative. The agency's filing of its motion for permanent custody complied with R.C. 2151.415(A) because the R.C. 2151.353(G) one-year temporary custody deadline neared. Temporary custody continued through disposition, and