In re T.M.

Citations

• 2023 Ohio 4475

Syllabus

Juv.R. 29 Adjudication Juv.R. 34 Disposition Consent Permanent Custody Ineffective Assistance of Counsel. The trial court did not err by accepting the father's consent to permanent custody nor did the trial court err by failing to advise the father regarding his right to appeal (at the conclusion of the permanent-custody hearing) since neither he nor his trial counsel were present at the conclusion of the hearing. Moreover, because we concluded that this appeal was timely filed, the appellant has suffered no prejudice and this issue is moot. Appellant failed to carry his burden as to the prejudice prong of his ineffective-assistance-of-counsel claim.