In re K.L.

Summary

The Ohio Eighth District Court of Appeals affirmed the juvenile court’s order awarding permanent custody of a minor child to the Cuyahoga County Division of Children and Family Services. The court held that clear and convincing evidence supported findings that the mother failed to substantially remedy the conditions leading to removal and had abandoned the child. The court did not address the best-interest determination because the mother did not challenge it on appeal.

Holdings

1. The juvenile court properly found by clear and convincing evidence that the child could not be placed with Mother within a reasonable time or should not be placed with her because Mother failed continuously and repeatedly to substantially remedy the conditions causing removal and abandoned the child.
2. The juvenile court properly found that Mother abandoned the child where she failed to visit or maintain contact with the child for more than ninety days.
3. The agency's efforts were sufficient under the circumstances, and Mother's reliance on In re L.H. did not establish reversible error.

Questions Presented

1. Whether the juvenile court's finding under R.C. 2151.414(B)(1)(a) that the child could not be placed with Mother within a reasonable time or should not be placed with Mother was against the manifest weight of the evidence.
2. Whether the agency made reasonable and diligent efforts to assist Mother with her case-plan objectives.

Disposition

affirmed