In re S.F.

Summary

The Ohio Twelfth District Court of Appeals affirmed the juvenile court's decision granting Warren County Children Services permanent custody of S.F. and denying the paternal grandmother's competing motion for legal custody. The court held that the permanent-custody decision was supported by sufficient evidence and was not against the manifest weight of the evidence, emphasizing the child's significant behavioral and mental-health needs and the grandmother's limited ability to provide specialized care.

Holdings

1. The grandmother lacked standing to challenge the termination of S.F.'s father's parental rights, but she had standing to challenge the effect of the permanent-custody decision on her competing motion for legal custody and her rights as S.F.'s legal custodian.
2. The juvenile court did not err in finding that permanent custody with Warren County Children Services was in S.F.'s best interest rather than legal custody with the grandmother.
3. The permanent-custody decision was not against the manifest weight of the evidence and was therefore supported by sufficient evidence.

Questions Presented

1. Whether the grandmother had standing to challenge the permanent-custody order.
2. Whether the juvenile court's determination that permanent custody with Warren County Children Services was in S.F.'s best interest, rather than legal custody with the grandmother, was against the manifest weight of the evidence.
3. Whether sufficient evidence supported the juvenile court's permanent-custody decision.

Disposition

affirmed