In re T.L.

Summary

The Ohio Fourth District Court of Appeals affirmed a judgment granting Pickaway County Job and Family Services permanent custody of T.L. The court held that the mother's stipulation to permanent custody was knowingly, voluntarily, and intelligently made under the totality of the circumstances, and that she failed to demonstrate prejudice from any omission in the trial court's Juv.R. 29(D) colloquy.

Holdings

1. The juvenile court substantially complied with Juv.R. 29(D) because the totality of the circumstances showed that Mother understood she was consenting to an order terminating her parental rights and granting permanent custody to the Agency, and that her stipulation was knowing, voluntary, and intelligent.
2. Even assuming the omission of Juv.R. 29(D)(2) invalidated Mother's admission, reversal was unwarranted because Mother failed to demonstrate prejudice.

Questions Presented

1. Whether the juvenile court violated Mother's due process rights by accepting her stipulation to permanent custody without determining that it was entered knowingly, voluntarily, and intelligently as required by Juv.R. 29(D).
2. Whether any omission in the juvenile court's colloquy concerning Juv.R. 29(D)(2) constituted plain error requiring reversal when the permanent-custody judgment was based on evidence beyond Mother's stipulation.

Disposition

affirmed