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2025 Ohio 752
Ohio Ct. App.
2025
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Background

  • The case involves the termination of parental rights for the father, An.M., regarding his twin children, following a history of abuse, neglect, and multiple removals by the Cuyahoga County Division of Children and Family Services (CCDCFS).
  • After an initial removal in 2020 for unexplained injuries, the children were later found in deplorable conditions in April 2024 under the care of a minor, leading to their hospitalization (one for severe malnutrition).
  • The father had minimal visitation, did not attend medical appointments, failed to provide support, and repeatedly refused to secure appropriate housing or participate in court-ordered services.
  • The agency filed for permanent custody in April 2024, and a case plan was designed with a goal of reunification, but the father's participation was negligible.
  • Following hearings in July and August 2024, the juvenile court granted permanent custody of the children to CCDCFS, terminating the father's parental rights.
  • The father appealed, challenging the sufficiency and weight of the evidence and the agency's reunification efforts.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Sufficiency of the evidence for termination Agency did not meet clear and convincing evidence standard Ample evidence of father's lack of involvement and failure to remedy issues Evidence was legally sufficient; termination affirmed
Manifest weight of the evidence Decision against manifest weight; not enough credible evidence Record supports statutory grounds for termination Decision was not against the manifest weight; affirmed
Reasonable efforts to reunify Agency failed to make reasonable efforts before seeking custody Reasonable efforts were made but father was non-compliant Agency made documented reasonable efforts; argument overruled

Key Cases Cited

  • State v. Schiebel, 55 Ohio St.3d 71 (standard for sufficiency and manifest weight of evidence in custody cases)
  • Cross v. Ledford, 161 Ohio St. 469 (definition of clear and convincing evidence standard)
  • Ford v. Osborne, 45 Ohio St. 1 (clarifies standard of appellate review for sufficiency challenges)
  • In re Schaefer, 111 Ohio St.3d 498 (no best-interest factor is given greater weight in permanent custody analysis)
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Case Details

Case Name: In re A.M.
Court Name: Ohio Court of Appeals
Date Published: Mar 6, 2025
Citations: 2025 Ohio 752; 114380; 114381
Docket Number: 114380; 114381
Court Abbreviation: Ohio Ct. App.
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