In re W.M.

Citations

• 2017 Ohio 1398

Syllabus

CHILDREN - CUSTODY: Where the magistrate's finding that mother had failed to remedy the conditions that had led to the removal of her children from her home was supported by competent and credible evidence, the trial court did not err in adopting the magistrate's decision granting permanent custody of the children to the Hamilton County Department of Job and Family Services. Although the reasonable-efforts requirement in R.C. 2151.419 does not apply to an R.C. 2151.413 motion for permanent custody, absent a narrowly defined statutory exception, the state must still make reasonable efforts to reunite the family during the custody proceedings prior to the termination of parental rights.