In re T.L.

Summary

The Sixth District Court of Appeals of Ohio affirmed an order awarding legal custody of a dependent child to the mother and granting the father supervised visitation at least once per month. The court held that the visitation order was not an abuse of discretion and was not impermissibly vague or violative of the father’s or child’s due process rights. The court also stated that the father could seek additional visitation orders or contempt remedies if the mother failed to comply.

Holdings

1. The juvenile court did not abuse its discretion by ordering father to have at least one supervised visit per month, with the possibility of additional visitation after he demonstrated a consistent pattern of healthy and meaningful visits.
2. The visitation order was not impermissibly vague and did not violate father’s or the child’s due process rights.
3. Father’s claim that the order improperly gave mother sole control over visitation was meritless because it was based on speculation about future noncompliance.

Questions Presented

1. Whether the juvenile court abused its discretion by ordering father to have at least one supervised visit with the child per month without specifying the duration of each visit.
2. Whether the visitation order was impermissibly vague and violated father’s or the child’s substantive due process rights.
3. Whether the juvenile court properly restricted visitation based on the child’s best interest, the child’s young age, father’s inconsistent visitation, failure to communicate with the agency, and failure to complete case-plan services.

Disposition

affirmed