In re E.A. and H.A.

Summary

The Fifth District Court of Appeals of Ohio affirmed the Coshocton County Juvenile Court's judgment terminating the mother's parental rights to twins E.A. and H.A. and awarding permanent custody to the Coshocton County Department of Job and Family Services. The court held that the mother was not denied due process because she had notice, an opportunity to be heard, and access to counsel, and because the statutory requirements for permanent custody were satisfied. The court also upheld the denial of a second six-month extension of temporary custody.

Holdings

1. The permanent-custody judgment did not violate due process because mother received notice, counsel, and an opportunity to present evidence at the permanent-custody proceedings, and the statutory requirements for permanent custody were satisfied.
2. The denial of a second six-month extension was not an abuse of discretion and did not violate due process.
3. The statutory requirements were met because the children had been in agency custody for at least twelve months of a consecutive twenty-two-month period and permanent custody was in their best interests.

Questions Presented

1. Whether granting CCJFS permanent custody rather than ordering further reunification efforts violated mother's due process right to parent her children.
2. Whether the juvenile court's denial of mother's request for a second six-month extension of temporary custody violated due process.
3. Whether the statutory requirements for permanent custody were satisfied based on the children's placement in agency custody for at least twelve months of a consecutive twenty-two-month period and their best interests.

Disposition

affirmed