In re A.M. (Slip Opinion), 2020 Ohio 5102

A.M. (born Nov. 2015) entered care after mother Brianna (a minor who later emancipated) exhibited instability, substance use, school problems, and sporadic visitation.
Hamilton County Department of Job and Family Services obtained protective supervision (Dec. 2016), temporary custody (Sept. 2017), and sought permanent custody (Mar. 2018).
Magistrate held a two-day evidentiary hearing (Sept. 2018) and found by clear and convincing evidence A.M. could not be placed with either parent and that permanent custody to the agency was in A.M.’s best interest.
Brianna objected on weight-of-evidence grounds; juvenile court independently reviewed the record, overruled the objection, and adopted the magistrate’s decision.
First District affirmed (split decision); Supreme Court accepted review on whether R.C. 2151.414(D)(1) requires written findings addressing each enumerated best-interest factor.

Issue	Plaintiff's Argument (Brianna)	Defendant's Argument (Dept.)	Held
Whether R.C. 2151.414(D)(1) requires a juvenile court to expressly analyze and make written findings as to each enumerated best-interest factor before awarding permanent custody	Statute requires the court to discuss and explain, in writing, how the record supports each R.C. 2151.414(D)(1)(a)–(e) factor so appellate review is meaningful	Statute requires only that the court "consider" the factors; no requirement to discuss each factor in the written decision, but the record must show consideration	Held: "consider" means reflect on/think about; R.C. 2151.414(D)(1) does not require written discussion or explicit factual findings for each factor. Court may encourage but not compel such written analysis; here record shows factors were considered, so judgment affirmed

In re C.F., 113 Ohio St.3d 73, 862 N.E.2d 816 (Ohio 2007) (describing statutory findings required before granting permanent custody)
In re B.C., 141 Ohio St.3d 55, 21 N.E.3d 308 (Ohio 2014) (agency bears burden to prove best interest by clear and convincing evidence)
In re T.R., 120 Ohio St.3d 136, 896 N.E.2d 1003 (Ohio 2008) (principles of statutory interpretation—apply plain meaning)
State v. Thompson, 92 Ohio St.3d 584, 752 N.E.2d 276 (Ohio 2001) (treating the word "consider" as meaning to reflect on or think about)
State v. Douglas, 20 Ohio St.3d 34, 485 N.E.2d 711 (Ohio 1985) (a statute or rule requiring consideration of factors does not necessarily require written findings for each factor)
State v. Cook, 83 Ohio St.3d 404, 700 N.E.2d 570 (Ohio 1998) (statute requiring consideration of enumerated factors does not mandate listing them in the decision)
State v. Eppinger, 91 Ohio St.3d 158, 743 N.E.2d 881 (Ohio 2001) (noting best practice of on-the-record discussion of statutory factors to aid appellate review)