In re R.S.

Summary

The Tenth District Court of Appeals of Ohio affirmed a juvenile court judgment granting Franklin County Children Services permanent custody of R.S. The court held that denying the father’s last-minute request for a continuance did not violate due process or constitute an abuse of discretion, given the case’s history, the child’s need for permanency, and the father’s minimal case-plan progress.

Holdings

1. The trial court did not abuse its discretion or violate due process by denying father's last-minute request to continue the permanent-custody hearing. The circumstances favored prompt resolution, and father failed to show that a continuance likely would have changed the outcome.

Questions Presented

1. Whether the trial court abused its discretion and violated father's due-process rights by denying his request to continue the permanent-custody hearing so that he could attend and testify.

Disposition

affirmed