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| Case Caption | Case No. | Topics and Issues | Author | Citation / County | Decided | Posted | WebCite |
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State v. Clark
| 8-25-04 | Intervention in Lieu of Conviction; R.C. 2951.041(F); Plain Error. For Plain error to apply, the trial court must have deviated from a legal rule; the error must have been an obvious defect in the proceeding; and the error must have affected a substantial right. R.C. 2951.041(F) governs the process of addressing an offender's failure to comply with the terms or conditions of his or her ILC. If an offender fails to comply with the terms or conditions of his or her intervention in lieu of conviction, the trial court may continue the period of the ILC, continue the ILC with additional terms or conditions, or may enter a finding of guilt and impose a sanction. | Willamowski | Logan |
11/17/2025
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11/17/2025
| 2025-Ohio-5173 |
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State v. Butler
| 14-25-18 | Offenses Committed Prior to March 22, 2019; R.C. 2929.14(A)(1)(b); Sentence is Clearly and Convincingly Contrary to Law; R.C. 2953.08(G)(2). The defendant-appellant’s sentence is clearly and convincingly contrary to law since the trial court imposed an indefinite prison term for a first-degree-felony offense committed prior to the enactment of the Reagan Tokes Law. The judgment of the trial court is reversed and the matter remanded for resentencing. | Zimmerman | Union |
11/17/2025
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11/17/2025
| 2025-Ohio-5176 |
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In re S.D.
| 6-25-05 | Due Process; Permanent-Custody Hearing. The trial court did not err by proceeding with the permanent-custody hearing in the absence of mother-appellant. | Miller | Hardin |
11/17/2025
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11/17/2025
| 2025-Ohio-5172 |
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Stone v. Humphress
| 5-25-06 | Contempt. Trial court erred by finding that appellee was not in contempt of court given the trial court's prior final decisions that were not appealed. | Waldick | Hancock |
11/17/2025
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11/17/2025
| 2025-Ohio-5171 |
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State v. Bonifas
| 15-25-02 | Sufficiency of Evidence; Manifest Weight; Aggravated Menacing. Defendant-appellant’s conviction for aggravated menacing is supported by sufficient evidence and is not against the manifest weight of the evidence. | Miller | Van Wert |
11/17/2025
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11/17/2025
| 2025-Ohio-5177 |
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State v. Loy
| 13-25-09 | Manifest Weight of the Evidence; Motion to Sever; Consecutive Sentences. The convictions were supported by credible evidence and does not indicate that the jury lost its way creating a manifest injustice. As such, the convictions were not against the manifest weight of the evidence. The trial court's decision not to sever the charges was not in error when no prejudice was alleged. Trial court made the required findings to impose consecutive sentences and the evidence supported the findings. | Willamowski | Seneca |
11/17/2025
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11/17/2025
| 2025-Ohio-5175 |
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Piacentino v. Heinz
| 9-24-51 | R.C. 2505.02(B)(4). Final appealable order; Preliminary Injunction. The trial court's judgment entry denying defendant-appellant's petition for a preliminary injunction is not a final, appealable order. | Miller | Marion |
11/17/2025
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11/17/2025
| 2025-Ohio-5174 |
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State v. Miller
| 2-25-05 | R.C. 2929.11; R.C. 2929.12; Appeal of maximum consecutive sentences. Appellate court lacks jurisdiction to review application of R.c. 2929.11 and 2929.12. Appellate court must affirm if 2929.11 and 2929.12 are considered and the sentence is within the statutory range. | Willamowski | Auglaize |
11/17/2025
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11/17/2025
| 2025-Ohio-5170 |
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State v. Hesseling
| 1-24-34 | Major Drug Offender Specification; R.C. 2929.14(B)(11); Drug Trafficking; Drug Possession; Constructive Possession; Ineffective Assistance of Counsel; Accomplice Jury Instruction; R.C. 2923.03(D). The trial court did not err in imposing a prison term for each of the major drug offender specifications. Defendant-appellant's convictions were supported by sufficient evidence and were not against the manifest weight of the evidence. Defendant-appellant was not denied effective assistance of counsel due to his trial counsel failing to file a motion to suppress and failing to object to certain alleged hearsay statements. The trial court did not commit plain error in failing to provide a cautionary instruction pursuant to R.C. 2923.03(D) concerning accomplice testimony. | Miller | Allen |
11/10/2025
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11/10/2025
| 2025-Ohio-5102 |
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State v. Averesch
| 12-24-05 | Motion to Suppress; Identified Citizen Informant; Reasonable Articulable Suspicion; Forfeiture; Excessive Fines. Motions to suppress present mixed questions of law and fact. When a dispatcher's information comes from an informant, courts must examine the tip to examine its weight and reliability. Informants fall into three general categories: (1) anonymous informants; (2) known informants; and (3) identified citizen informants. Information from an identified citizen informant is generally considered to be more reliable. The forfeiture of a vehicle pursuant to R.C. 4511.19(G)(1)(c)(v) is a fine used to punish an offender. To determine whether an in personam forfeiture under this provision is excessive, courts are to examine whether the forfeiture is grossly disproportional to the gravity of the offense. | Willamowski | Putnam |
11/10/2025
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11/10/2025
| 2025-Ohio-5106 |
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State v. Bolen
| 6-25-12 | Allied Offenses; Consecutive Sentences; Crim.R. 11 Colloquy; Guilty Plea. In order to impose consecutive sentences, the trial court must make the findings required by R.C. 2929.14(C)(4). Allied offenses of similar import are to merge at sentencing. Merger is not required where offenses are dissimilar in import; were committed separately; or committed with separate animus. In examining a Crim.R. 11 colloquy to determine if a plea was knowingly, voluntarily, and intelligently entered, a reviewing court examines whether (1) the trial court has complied with the relevant provisions of the rule; (2) whether any failure to fully comply with the rule requires a demonstration of prejudice to vacate the plea; (3) whether the defendant has demonstrated prejudice where required for a failure to comply with Crim.R. 11. | Willamowski | Hardin |
11/10/2025
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11/10/2025
| 2025-Ohio-5104 |
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Bigler v. Haynes
| 9-25-10 | Appellate Rules of Procedure; Record; Appellate Review; Transcript. Appellate review is strictly limited to the matters contained in the record. The appellant has the burden of demonstrating that the trial court erred on appeal. App.R. 16 requires that the appellant provide arguments to substantiate the assignments of error raised on appeal. | Willamowski | Marion |
11/10/2025
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11/10/2025
| 2025-Ohio-5105 |
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State v. Horton
| 1-24-62 | Motion to Suppress; Consent to Search; Ineffective Assistance of Counsel; Custodial Interrogation. The trial court did not err in denying defendant-appellant's motion to suppress the drugs found during the search of his home because his consent to the search was freely and voluntarily given. Trial counsel was not ineffective in failing to timely file a motion to suppress on Miranda grounds because defendant-appellant did not show such a motion had a reasonable probability of success. Defendant-appellant's drug possession conviction was not against the manifest weight of the evidence. | Miller | Allen |
11/10/2025
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11/10/2025
| 2025-Ohio-5103 |
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In re R.P.
| 1-25-05 | Restitution; R.C. 2152.20; Receiving Stolen Property; 2913.51(A). The trial court did not abuse its discretion in determining the amount of restitution suffered by the victim as a direct and proximate result of appellant's delinquent act. | Miller | Allen |
11/3/2025
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11/3/2025
| 2025-Ohio-4997 |
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State v. Shipley
| 14-25-02 | Sufficiency of the Evidence; Manifest Weight of the Evidence; Robbery; R.C. 2911.02(A)(3); Theft; R.C. 2913.02(A)(1); Force; Prosecutorial Misconduct; Witness Vouching; Commenting on Decision Not to Testify; Misstatement of Law. The defendant-appellant’s robbery conviction is based on sufficient evidence and is not against the manifest weight of the evidence. The defendant-appellant was not deprived of a fair trial due to prosecutorial misconduct. | Zimmerman | Union |
11/3/2025
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11/3/2025
| 2025-Ohio-5001 |
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In re Adoption of T.M.Z.
| 13-25-07 | CONTESTED ADOPTION; R.C. 3107.01(A); NO CONTACT WITH MINOR; JUSTIFIABLE CAUSE; MANIFEST WEIGHT OF THE EVIDENCE; R.C. 3107.161(B); BEST-INTEREST DETERMINATION; ABUSE OF DISCRETION; ADMISSION OF EVIDENCE; R.C. 3107.031; HOME STUDY. The record does not contain credible evidence that the biological mother intentionally concealed the minor child’s whereabouts. Therefore, the trial court’s determination that the biological father-appellant was without justifiable cause for his failure to have contact with the child during the one-year period immediately preceding the filing of the adoption petition is not against the manifest weight of the evidence. The record reflects that the trial court considered the factors set forth in R.C. 3107.161(B) in making its best-interest determination. Thus, the trial court did not abuse its discretion in granting the petitioner-stepfather’s adoption petition. The trial court appointed an assessor to conduct a home study of the petitioner-stepfather’s home. The purpose of a home study is to ascertain whether a person seeking to adopt a minor is suitable to adopt. The trial court did not abuse its discretion by admitting the assessor’s report filed in compliance with R.C. 3107.031. | Zimmerman | Seneca |
11/3/2025
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11/3/2025
| 2025-Ohio-5000 |
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State ex rel. Pelmear v. Henry Cty. Land Reutilization Corp.
| 7-25-05 | Open Meetings Act; R.C. 121.22; Discovery; Civ.R. 26(B); Civ.R. 34; Discovery Sanction; Admission of Evidence; Injunctive Relief; Burden of Proving an Open Meetings Act Violation. The trial court did not abuse its discretion by denying the relator-appellant’s objection to the respondents-appellees’ reliance on its exhibits or by admitting the respondents-appellees’ exhibits at trial because the relator-appellant failed to use the proper procedural tools under Civ.R. 34 to obtain the documents. Because the relator-appellant failed to satisfy his burden of proving that the respondents-appellees violated Ohio’s Open Meetings Act under R.C. 121.22(F), the trial court did not abuse its discretion by denying the relator-appellant’s requested injunctive relief. | Zimmerman | Henry |
11/3/2025
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11/3/2025
| 2025-Ohio-4998 |
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In re G.N.
| 10-24-09 & 10-24-10 | Permanent Custody; Best Interest; Manifest Weight of the Evidence; In Camera Interview; Evidence; Hearsay; Kinship. The trial court’s decision granting the Agency permanent custody was supported by clear and convincing evidence. The trial court did not abuse its discretion by denying Mother-appellant’s motion for an in-camera interview. Mother-appellant and Father-appellant’s arguments relating to the shelter-care hearing and adjudication hearings were not timely. | Miller | Mercer |
11/3/2025
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11/3/2025
| 2025-Ohio-4999 |
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State v. Gingerich
| 14-25-10 | Misdemeanor Sentencing; R.C. 4511.21; R.C. 2929.22; R.C. 2929.24. The trial court sentenced the defendant-appellant to 60 days in jail with 30 days suspended on a third-degree misdemeanor. Absent an affirmative showing that the trial court failed to consider the applicable statutory factors, this court will presume that the trial court considered the criteria set forth in R.C. 2929.22 when imposing a misdemeanor sentence. | Zimmerman | Union |
10/27/2025
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10/27/2025
| 2025-Ohio-4908 |
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State v. Clay
| 8-25-01 | Review of consecutive sentences; R.C. 2929.14(C)(4); Misstatement of name of crime by trial judge at sentencing. The judgment of sentence is affirmed. | Waldick | Logan |
10/27/2025
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10/27/2025
| 2025-Ohio-4905 |
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Hoover v. Pfeifer
| 16-25-06 | Easements; Civ.R. 15(B); Motions to Amend Pleadings to Conform to the Evidence; Standing; Summary Judgment; Declaratory Judgment. The trial court did not err in granting summary judgment, declaratory judgment, and a permanent injunction in favor of the plaintiffs-appellees. | Waldick | Wyandot |
10/27/2025
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10/27/2025
| 2025-Ohio-4909 |
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Horne v. Adena Pointe Homeowners Assn., Inc.
| 14-25-03 | Summary Judgment; Declaratory Judgment; Business Judgment Rule; R.C. 5312.16. The trial court erred by granting summary judgment in favor of the plaintiffs-appellees, as the plaintiffs-appellees failed to carry their burden of proving that the homeowners’ association’s restrictions were unreasonable as a matter of law. However, because genuine issues of material fact remain on the undeveloped record, the defendants-appellants were also not entitled to summary judgment. | Zimmerman | Union |
10/27/2025
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10/27/2025
| 2025-Ohio-4916 |
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State v. Clapsaddle
| 6-24-17 | Rape; Gross Sexual Imposition; Evid.R. 404(B); Other Acts Evidence; Ineffective Assistance of Counsel; Rebuttal Testimony. The conviction for gross sexual imposition was supported by sufficient evidence. The conviction for rape was supported by sufficient evidence and was not against the manifest weight of the evidence. The trial court did not commit plain error in allowing other-acts evidence to be introduced by the State. Defendant-appellant did not show that his trial counsel rendered ineffective assistance. The trial court did not err by allowing the State to offer rebuttal testimony after the Defense rested its case. | Miller | Hardin |
10/27/2025
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10/27/2025
| 2025-Ohio-4904 |
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State v. Downton
| 1-25-32 | Violating a Protection Order; R.C. 2919.27(A)(2); Manifest Weight of the Evidence. The defendant-appellant’s violating a protection order conviction is not against the manifest weight of the evidence because the weight of the evidence presented at trial reflected that she did not immediately depart the public place when she accidentally encountered the victim as required by the protection order. | Zimmerman | Allen |
10/27/2025
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10/27/2025
| 2025-Ohio-4903 |
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State v. Paul
| 10-25-07 | Crim.R. 43(A); Defendant's presence in courtroom; Waiver of right to be present; Harmless error; Plain error; R.C. 2929.13(D); Presumption for prison not overcome; Court-appointed counsel costs; R.C. 2941.51; Civil assessment. The judgment of conviction and sentence entered against the defendant-appellant is affirmed. | Waldick | Mercer |
10/27/2025
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10/27/2025
| 2025-Ohio-4907 |
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State v. Hobson
| 1-24-58 | Operating a Vehicle Under the Influence of Alcohol ("OVI"); Probable cause to arrest for OVI; Sufficiency of evidence and manifest weight of the evidence relating to impairment while driving. The judgment of conviction and sentence is affirmed. | Waldick | Allen |
10/27/2025
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10/27/2025
| 2025-Ohio-4901 |
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State v. Jones
| 1-25-07 | Self-Defense; Recklessness; Manifest Weight; Sufficient Evidence; Nondeadly Force. Recklessness is defined as disregarding, with heedless indifference to the consequences, a substantial and unjustifiable risk that the person's conduct is likely to cause. If the defendant produces sufficient evidence to create an issue as to each of the elements of the affirmative defense of self-defense, the State has the burden of disproving at least one of the elements of self-defense beyond a reasonable doubt. If the defendant was at fault in creating the affray, he or she cannot claim self-defense. | Willamowski | Allen |
10/27/2025
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10/27/2025
| 2025-Ohio-4902 |
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State v. Greenawalt
| 9-24-40 | Self-Defense; Jury Instruction; Separation of Witnesses; Prior Inconsistent Statements; Cumulative Error. To raise the affirmative defense of self-defense at trial, the defendant must produce evidence that tends to support the conclusion that his or her use of force was justified. To warrant a jury instruction on self-defense, the defendant must produce evidence that (1) he or she was not at fault in creating the situation that led to the affray; (2) he or she had a bona fide belief that the use of force was the only way to escape an imminent threat of death or great bodily harm; (3) he or she did not violate any applicable duty to retreat. A separation order is issued to prevent witnesses from hearing the testimony of others and tailoring their statements accordingly. Issues relating to the separation of witnesses are entrusted to the discretion of the trial court. If a witness admits to making a prior inconsistent statement, a trial court does not abuse its discretion in excluding extrinsic evidence of that prior inconsistent statement. | Willamowski | Marion |
10/27/2025
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10/27/2025
| 2025-Ohio-4906 |
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State v. Kittle
| 2-25-02 & 2-25-03 | Felony Sentencing; R.C. 2929.11; R.C. 2929.12. Defendant-appellant's prison sentence is not clearly and convincingly contrary to law. | Miller | Auglaize |
10/20/2025
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10/20/2025
| 2025-Ohio-4793 |
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In re P.S.
| 6-25-03 & 6-25-04 | Permanent Custody; Reasonable Efforts; Sunset Date. Trial court's determination to grant permanent custody to children's services agency was not against the weight of the evidence. In addition, trial court did not err by determining agency engaged in reasonable efforts to support reunification. | Waldick | Hardin |
10/14/2025
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10/14/2025
| 2025-Ohio-4726 |
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State v. Murphy
| 10-25-05 | Pretrial Delay; Constitutional Right to a Speedy Trial; Withdrawal of Guilty Plea; Criminal Rule 43; and Effectiveness of Counsel. The trial court did not violate Criminal Rule 43 when it required the defendant to appear remotely when no objection was made and no prejudice to the defendant is shown. Trial court did not err in denying the motion to withdraw the guilty plea when it weighed the factors for granting it and determined that they fell against granting the motion. Constitutional right to a speedy trial was waived by defendant and was fully considered by the trial court. Counsel was not ineffective for failing to raise the speedy trial issue when it was considered and denied by the trial court. | Willamowski | Mercer |
10/14/2025
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10/14/2025
| 2025-Ohio-4713 |
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Williams v. D&J House Doctors, L.L.C.
| 13-25-08 | Summary Judgment; "As Is" Clause; Fraud; Bad Faith Claim. An "as is" clause in a purchase agreement for fraud will not bar a claim of positive fraud against the seller of the property. Unlike a claim for negligence, a buyer must prove that the seller had some knowledge of the defect in question where an "as is" clause is contained in the purchase agreement. R.C. 5302.30 directs sellers to complete a residential property disclosure form. However, this document is not a warranty. Thus, the purchaser has a duty to inspect the premises and is charged with knowledge of the conditions that a reasonable inspection would uncover. | Willamowski | Seneca |
10/14/2025
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10/14/2025
| 2025-Ohio-4716 |
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In re K.S.
| 11-25-06 | Delinquency; Sufficiency; Manifest Weight. Juvenile adjudications were supported by the evidence and were not against the weight of the evidence. | Waldick | Paulding |
10/14/2025
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10/14/2025
| 2025-Ohio-4715 |
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State v. Wyne
| 8-25-05 | Court Costs, Waiver. Trial court did not err by not waiving court costs when no motion was made to do so and the record contains insufficient evidence to grant the waiver sua sponte. | Willamowski | Logan |
10/14/2025
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10/14/2025
| 2025-Ohio-4712 |
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In re K.B.
| 11-25-05 | Manifest Weight of the Evidence; Breaking and Entering; Vandalism; Identity; Evidence Admissibility; Authentication; Evid.R. 901. The child-appellant’s breaking and entering and vandalism adjudications were not against the manifest weight of the evidence. The trial court did not abuse its discretion by admitting photographs into evidence because the State properly authenticated the photographs by presenting testimony from a witness with personal knowledge of the scene. | Zimmerman | Paulding |
10/14/2025
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10/14/2025
| 2025-Ohio-4714 |
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State v. Parsons
| 7-25-01 | Motion For Leave For A New Trial; Crim.R. 33; Unavoidably Prevented: Brady v. Maryland. The trial court did not abuse its discretion by partially denying the defendant-appellant’s motion for leave to file a motion for a new trial because the defendant-appellant did not carry his burden of demonstrating a Brady violation. Therefore, the defendant-appellant was not unavoidably prevented from discovering the new evidence. | Zimmerman | Henry |
10/6/2025
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10/6/2025
| 2025-Ohio-4626 |
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State v. Light
| 14-25-08 | Plea Withdrawal; Ineffective Counsel. Trial court did not abuse its discretion by denying presentence motion to withdraw guilty plea. | Waldick | Union |
10/6/2025
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10/6/2025
| 2025-Ohio-4628 |
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State v. Bleam
| 16-25-02 | Guilty Plea to Petty Offense; Crim.R. 11(E). The trial court did not err in fulfilling its obligations for accepting defendant-appellant's guilty plea to the petty offense. | Miller | Wyandot |
10/6/2025
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10/6/2025
| 2025-Ohio-4629 |
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In re X.G.
| 8-24-42 | Permanent Custody; R.C. 2151.414. The trial court’s decision to grant permanent custody of the child to the agency is not against the manifest weight of the evidence. Clear and convincing evidence supports the trial court’s finding that the child cannot be placed with either parent within a reasonable period of time or should not be placed with either parent, and that it was in the child’s best interest that the agency be granted permanent custody. | Zimmerman | Logan |
10/6/2025
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10/6/2025
| 2025-Ohio-4627 |
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In re B.S.
| 17-24-16, 17-24-18, 17-24-19 | Permanent Custody; Best Interest; Reasonable Efforts; Manifest Weight of the Evidence; In Camera Interview; Kinship Caregiver Act; R.C. 2951.4117; Plain Error. The trial court’s decision granting the Agency permanent custody was supported by clear and convincing evidence. Mother-appellant’s arguments relating to the trial court’s compliance with the Kinship Caregiver Act are untimely. The trial court did not commit reversible error by not appointing an attorney for the children. | Miller | Shelby |
9/29/2025
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9/29/2025
| 2025-Ohio-4518 |
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State v. Cobb
| 8-25-03 | Adequacy of Counsel; Duty to Investigate. The trial court did not err in failing to inquire into the adequacy of counsel when the statements made by defendant during the trial regarding counsel's performance contained no specific allegations. Without the specific allegations, the trial court had no duty to investigate the performance. | Willamowski | Logan |
9/29/2025
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9/29/2025
| 2025-Ohio-4515 |
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Kemmler v. Kemmler
| 10-25-06 | Withholding Order; Abuse of Discretion. Under R.C. 3121.441(A), a trial court may permit an obligor to make spousal support payments directly to the obligee if no minor children were born as the result of the marriage. This issue is committed to the discretion of the trial court. Before rendering a decision, a trial court must fully consider the circumstances of a case before issuing a judgment. | Willamowski | Mercer |
9/29/2025
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9/29/2025
| 2025-Ohio-4516 |
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State v. Soto
| 12-24-06 | Final and Appealable Order; Plea Agreement; Motion to Dismiss Indictment. The trial court's order denying defendant-appellant's motion to enforce his plea agreement and dismiss the criminal case was a final, appealable order. For two independent reasons, the trial court did not err in denying the motion. First, circumstances for applying the principles from Supreme Court of Ohio caselaw on which defendant-appellant's appeal relies are absent from the peculiar facts and scenario presented. Second, defendant-appellant breached the plea agreement, so he is barred from attempting to enforce it against the State to dismiss the current indictment. | Miller | Putnam |
9/29/2025
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9/29/2025
| 2025-Ohio-4517 |
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State v. Fisher
| 1-24-74 | Sentencing; Bias; Consecutive Sentences. Trial court did not demonstrate bias when statements were viewed in context. Defendant did not demonstrate that sentence was clearly and convincingly contrary to law. | Waldick | Allen |
9/22/2025
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9/22/2025
| 2025-Ohio-4412 |
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State v. Tucker
| 3-25-07 | Allied Offenses of Similar Import, Merger. Trial court did not err in declining to merge the convictions when the offenses were committed separately and caused separate harm. | Willamowski | Crawford |
9/22/2025
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9/22/2025
| 2025-Ohio-4413 |
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State v. Gochenour
| 14-25-07 | Sentencing Factors; R.C. 2929.11; R.C. 2929.12; Ineffective Assistance of Counsel. Appellate court lacks jurisdiction to consider the application of the sentencing factors. Counsel was not ineffective for not raising all the factors that possibly could have been raised in mitigation when the trial court indicated it had considered those factors. Counsel was not ineffective for failing to raise a letter written to the court by the defendant's mother when there was no indication counsel even knew it existed. | Willamowski | Union |
9/22/2025
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9/22/2025
| 2025-Ohio-4414 |
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Morrison v. Dible
| 16-25-01 | Domestic violence civil protection order; R.C. 3113.31; Menacing by stalking; R.C. 2903.211; First Amendment; Freedom of speech. The trial court did not err in granting the petitioner-appellee's petition for a domestic violence civil protection order as the pattern of conduct of the respondent-appellant giving rise to the protection order is not protected by his First Amendment right to free speech. | Waldick | Wyandot |
9/22/2025
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9/22/2025
| 2025-Ohio-4415 |
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Houle v. Broters
| 13-25-03 | Modification of Custody; Access to Visitation Summaries; Independent Review; Abuse of Discretion. The trial court did not abuse its discretion in finding a change of circumstances and determining that a modification of custody would be in the child's best interest when the decision is supported by substantial credible evidence. Trial court conducted an independent review. | Willamowski | Seneca |
9/15/2025
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9/15/2025
| 2025-Ohio-4321 |
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In re B.L.
| 5-24-42; 5-24-44; 5-24-45 | Permanent Custody; R.C. 2151.414(B)(1)(d); Legal Custody; R.C. 2151.353(A); Reasonable Efforts Toward Reunification; R.C. 2151.419. The trial court did not err by awarding permanent custody of the children to the agency. The trial court did not abuse its discretion by denying the grandparents-appellants’ motions for legal custody of the children. The trial court did not abuse its discretion by determining that the agency made reasonable efforts toward reunification. | Zimmerman | Hancock |
9/15/2025
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9/15/2025
| 2025-Ohio-4320 |
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In re B.S.
| 4-25-03 | Permanent Custody; Facial Constitutionality of a Statute; R.C. 2151.414(C); Waiver; Ineffective Assistance of Counsel. By failing to raise her constitutional argument in the trial court, the mother-appellant waived the issue for appeal. Mother-appellant’s trial counsel was not ineffective for failing to raise her constitutional claim because she cannot demonstrate prejudice given that courts have consistently rejected similar constitutional challenges to R.C. 2151.414. | Zimmerman | Hancock |
9/15/2025
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9/15/2025
| 2025-Ohio-4318 |
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