In re X.P.

Summary

The Ohio Fourth District Court of Appeals reviews a judgment awarding Scioto County Children Services permanent custody of two children adjudicated neglected or dependent. The biological mother challenged the finding that permanent custody was in the children's best interests, while the record addressed the parents' substance-abuse treatment, housing, visitation, paternity, foster placement, and the children's bonds and wishes. The opinion applies the clear-and-convincing-evidence and manifest-weight standards under Ohio's permanent-custody statutes.

Holdings

1. A reviewing court will not disturb a permanent-custody decision unless it is against the manifest weight of the evidence; the court must determine whether the juvenile court's findings were supported by clear and convincing evidence.
2. When an agency seeks permanent custody after obtaining temporary custody, the court applies R.C. 2151.414, which permits permanent custody when clear and convincing evidence establishes that permanent custody serves the child's best interest and the child has been in agency temporary custody for twelve or more months of a consecutive twenty-two-month period.
3. The juvenile court's finding that permanent custody with Scioto County Children Services served the children's best interests was supported by clear and convincing evidence and was not against the manifest weight of the evidence.

Questions Presented

1. Whether the juvenile court's determination that permanent custody with Scioto County Children Services served the children's best interests was supported by clear and convincing evidence.
2. Whether the juvenile court's permanent-custody judgment was against the manifest weight of the evidence.

Disposition

affirmed