In re Y.G., et al.

Summary

The Eighth District Court of Appeals of Ohio affirmed juvenile court orders concerning six minor children, including permanent custody to Cuyahoga County Children and Family Services, legal custody to caregivers, and placement of one child in a planned permanent-living arrangement. The court held that the juvenile court’s findings under Ohio Revised Code Chapter 2151 and its best-interest determinations were supported by the manifest weight of the evidence. The court also addressed the parent’s fundamental liberty interest in the care and custody of her children and the applicable clear-and-convincing-evidence standard.

Holdings

1. The juvenile court's findings under R.C. 2151.414(B)(1)(a) and (B)(1)(d) were supported by the evidence and satisfied the first prong of the permanent-custody analysis.
2. Permanent custody of A.G., Jayc.G., and Jayv.G. was in their best interests, and the juvenile court's determination was not against the manifest weight of the evidence.
3. The juvenile court properly placed Y.G. in a planned permanent living arrangement because she was at least sixteen, had developmental disabilities, and the PPLA was supported by clear and convincing evidence as being in her best interests.
4. The juvenile court properly granted legal custody of T.G. and L.G. to their respective caregivers because the dispositions were supported by a preponderance of the evidence and were in the children's best interests.

Questions Presented

1. Whether the juvenile court's finding that the statutory grounds for permanent custody existed was against the manifest weight of the evidence.
2. Whether permanent custody of A.G., Jayc.G., and Jayv.G. was in the children's best interests under R.C. 2151.414(D).
3. Whether placement of Y.G. in a planned permanent living arrangement was supported by the statutory requirements and the manifest weight of the evidence.
4. Whether placement of T.G. and L.G. in the legal custody of their respective caregivers was in their best interests.

Disposition

affirmed