In re J.H.

2026-Ohio-1333 · Court of Appeals of Ohio, Third Appellate District, Allen County · April 13, 2026 · No. 1-25-40

Summary

The Ohio Third District Court of Appeals affirmed the judgment granting Allen County Children Services permanent custody of J.H., an adjudicated dependent and abused child. The court held that clear and convincing evidence supported the finding that permanent custody was in J.H.’s best interest and that the trial court did not abuse its discretion by denying the mother’s request for a temporary-custody extension.

Holdings

  1. The permanent-custody award was supported by clear and convincing evidence and was not against the manifest weight of the evidence.
  2. The juvenile court did not abuse its discretion by denying Jessica's request for a two-month extension.

Questions Presented

  1. Whether the juvenile court's determination that permanent custody was in J.H.'s best interest was against the manifest weight of the evidence.
  2. Whether the juvenile court abused its discretion by denying Jessica's request for a two-month extension of temporary custody to obtain suitable housing.

Disposition

affirmed

Cases Cited (23)

  • In re Dn.R., 2020-Ohio-6794, ¶¶ 16-19 (3d Dist.)(followed)
  • Eastley v. Volkman, 2012-Ohio-2179, ¶ 20(followed)
  • Tewarson v. Simon, 141 Ohio App.3d 103, 115 (9th Dist. 2001)(followed)
  • In re K.H., 2008-Ohio-4825, ¶ 43(followed)
  • In re Estate of Haynes, 25 Ohio St.3d 101, 104, 25 Ohio B. 150 (1986)(followed)
  • State v. Schiebel, 55 Ohio St.3d 71, 74 (1990)(followed)
  • In re R.M., 2013-Ohio-3588, ¶ 55 (4th Dist.)(followed)
  • In re S.D., 2016-Ohio-7057, ¶ 20 (5th Dist.)(followed)
  • State v. Thompkins, 78 Ohio St.3d 380, 387 (1997)(followed)
  • State v. Martin, 20 Ohio App.3d 172, 175, 20 Ohio B. 215 (1st Dist. 1983)(followed)

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