In re R.B.

Summary

The Ohio Twelfth District Court of Appeals affirmed a juvenile court decision granting Warren County Children Services permanent custody of a child. The court held that the father did not challenge the finding that the child had been in agency custody for at least 12 of 22 consecutive months and concluded that permanent custody was in the child's best interest based on the parents' circumstances and parenting limitations.

Holdings

1. Only one of the findings listed in R.C. 2151.414(B)(1)(a) through (e) is required to satisfy the second prong of Ohio's two-part permanent-custody test. Because Father did not challenge the juvenile court's finding that the child had been in the Agency's temporary custody for at least 12 months of a consecutive 22-month period, the appellate court did not need to review that issue further.
2. The juvenile court properly found by clear and convincing evidence that awarding permanent custody to the Agency was in the child's best interest.
3. The judgment was supported by clear and convincing evidence and was not against the manifest weight of the evidence.

Questions Presented

1. Whether the juvenile court properly found by clear and convincing evidence that awarding permanent custody to Warren County Children Services was in the child's best interest under R.C. 2151.414(D).
2. Whether the permanent-custody judgment was against the manifest weight of the evidence.

Disposition

affirmed