Maternal Grandmother v. Hamilton Cty. Job & Family Servs.

PARENTAL TERMINATION — PERMANENT CUSTODY — EVIDENCE — MANIFEST WEIGHT — BEST INTEREST OF THE CHILD — LEGALLY SECURE PLACEMENT — ABANDONMENT: Where Mother failed to assert in her objection to the magistrate's decision that the magistrate's decision was not supported by sufficient evidence, and she did not advance a plain-error argument on appeal, she has failed to preserve this argument for appeal. The juvenile court's decision to commit the children to the permanent custody of the Hamilton County Department of Job and Family Services was not contrary to the manifest weight of the evidence where the evidence demonstrated that permanent custody was in the children's best interest where the record and testimony showed that the children had been in the agency's care for approximately 16 consecutive months, and Mother (1) failed to visit the children for nearly three years, (2) refused to sign a release of information so that she could be referred for services, including making a referral so that Mother could continue supervised visits, (3) failed to remedy the concerns regarding her housing, including having working utilities, and (4) failed to verify her income. The juvenile court's finding that the children could not be placed with Mother within a reasonable time or should not be placed with Mother was not contrary to the manifest weight of the evidence where the evidence demonstrated that she did not remedy the issues that initially caused the children to be removed from her care.

R.C. 2151.414 – PARENTAL TERMINATION – BEST INTEREST: The juvenile court's grant of permanent custody of Mother's children to the Hamilton County Department of Job and Family Services was supported by sufficient evidence and was not contrary to the manifest weight of the evidence where the record showed Mother failed to manage her bipolar disorder and failed to remedy the cause that prompted the children's removal.

PARENTAL TERMINATION — PERMANENT CUSTODY —REASONABLE EFFORTS — EVIDENCE — SUFFICIENCY — MANIFEST WEIGHT: The juvenile court's decision to commit the children to the permanent custody of the Hamilton County Department of Job and Family Services was based on competent, credible evidence where the parents' visitation never progressed from supervised, they failed to obtain stable housing and income and submit to drug tests, they did not demonstrate understanding of the children's trauma and special needs, and although the parents obtained housing they did so less than four months prior to the trial on the permanent-custody motion and had no furniture for the children in the home. Where Mother failed to assert in her objections to the magistrate's decision that the juvenile court did not make reasonable-efforts findings, she has failed to preserve this argument for appeal.