In re A.D., 2021 Ohio 4583

A.D., born December 24, 2019, was exposed to drugs in utero and was in the NICU; Summit County Children Services Board (CSB) filed a complaint on January 10, 2020 alleging abuse, neglect, and dependency.
Mother stipulated that A.D. was abused and dependent; Father was absent at adjudication and the juvenile court adjudicated A.D. abused and dependent and placed the child in CSB temporary custody.
The court adopted agency case plans (original and amended) with objectives for both parents.
About 11 months after filing, CSB moved for permanent custody, alleging parents’ chronic substance abuse, failure to remedy conditions, lack of commitment, and inability/unwillingness to provide basic needs.
The juvenile court found A.D. could not or should not be returned to either parent based on lack of commitment and awarded permanent custody to CSB, terminating both parents’ rights. Father appealed, raising (1) lack of appellate jurisdiction due to a typographical case-number error on the judgment and (2) that CSB failed to provide reasonable reunification efforts and adequate case plans.

Issue	Father's Argument	CSB's Argument	Held
Whether the appellate court has jurisdiction because the juvenile court's judgment contained a typographical error in the case number	Typographical error in the case number (wrong month) renders the judgment non-final and deprives appellate court of jurisdiction	The record contains correct case identifiers (barcode, journal entry), Civ.R. 58(B) notice was filed, appellant was not prejudiced and had access to the correct record; the typo is immaterial	Court held the typo did not render the judgment non-final; appellate jurisdiction exists (assignment overruled)
Whether CSB failed to use reasonable reunification efforts and whether case plans complied with federal law	CSB did not make reasonable reunification efforts; case plan noncompliant with federal law	Juvenile court repeatedly found reasonable efforts at shelter, adjudication, disposition, and review hearings; Father did not object or move to set aside those findings (forfeited except for plain error); no prejudice shown	Court held Father forfeited the challenge, presumed regularity of prior reasonable-effort findings, rejected federal-law argument, and affirmed permanent custody (assignment overruled)

In re C.F., 113 Ohio St.3d 73 (2007) (a reasonable-efforts determination at a permanent-custody hearing is required only if the agency has not already established reasonable efforts prior to that hearing).