In re T.T.

Citations

• 2024 Ohio 2914

Syllabus

Permanent custody trial pro se right to counsel R.C. 2151.353 Juv.R. 4(A) waived circumstances continuance appointed counsel plain error R.C. 2151.414(B)(1)(d) harmless error R.C. 2151.414(B)(1)(a) R.C. 2151.414(E) best interest R.C. 2151.414(D)(1) clear and convincing sufficiency manifest weight. Affirmed the juvenile court's judgment granting permanent custody of the child to the agency and terminating father's parental rights. The totality of circumstances demonstrated that father waived his right to counsel for the first day of trial and chose to proceed pro se, and reversal under the plain-error doctrine was not warranted when father was appointed counsel for the second day of trial and was afforded the opportunity to present his case through counsel. Although the juvenile court erred in making a finding pursuant to R.C. 2151.414(B)(1)(d), the error was harmless when R.C. 2151.414(B)(1)(a) was also found to apply. The evidence was legally sufficient to support the juvenile court's decision, and the court's decision was not against the manifest weight of the evidence.