In re A.F., 103 N.E.3d 1260

Agency removed infant A.F. from parents in 2014 after hospital concerns (parents reportedly asleep, hygiene issues) and placed her with paternal relatives M.B. and P.B.; relatives' home approved in a home study.
Parents participated in services and supervised visitation, but the Agency and evaluator Dr. Bromberg found persistent problems: Mother has extremely low intellectual functioning (IQ ~59), personality disorder features, and limited parenting insight; Father has medical issues, defensive/test-minimizing responses, anger issues, and possible personality/mood concerns.
Visitation reports and assessments described parental detachment, Mother's repeated angry "no" to the child, instances suggesting risk to the child, and Father’s tendency to acquiesce to Mother rather than provide effective supervision.
After roughly 17–24 months of services with limited meaningful progress, the juvenile court denied a second extension of temporary custody and awarded legal custody to M.B. and P.B., granting supervised parenting time to Mother and Father.
Parents appealed (Mother: argued the court should have granted a further temporary-custody extension; Father: argued the Agency failed to make reasonable reunification efforts). The appellate court affirmed the juvenile court's legal-custody decision.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court erred by granting legal custody to relatives instead of a second extension of temporary custody	Mother: she (and Father) complied with services and made progress; reunification within an extension was reasonably likely	Agency/Juvenile Ct: parents engaged but made no significant progress; child is bonded to relatives and would be at risk if returned	Court: Denied extension and granted legal custody; decision was supported by preponderance and not an abuse of discretion
Whether the Agency failed to make reasonable efforts to enable reunification	Father: Agency gave insufficient time, failed to provide housing/job referrals, and kept visitation supervised despite adequate parenting	Agency/Juvenile Ct: provided evaluations, referrals, long-term treatment and parenting services; supervised visitation was warranted by safety concerns	Court: Agency made reasonable efforts; timing and supervised visitation were justified given risks and lack of parental progress

Miller v. Miller, 37 Ohio St.3d 71 (trial-court custody discretion deserves deference)
Trickey v. Trickey, 158 Ohio St. 9 (trial court's opportunity to observe witnesses warrants deference)
Seasons Coal Co. v. City of Cleveland, 10 Ohio St.3d 77 (credibility disputes are not grounds for reversal)
Thompkins v. Ohio, 78 Ohio St.3d 380 (manifest-weight standard explained)
Eastley v. Volkman, 132 Ohio St.3d 328 (application of manifest-weight standard in civil cases)