Background - A.P., born 2014, was adjudicated a dependent child after LCCS alleged parental substance abuse and father’s incarceration for domestic violence; LCCS obtained temporary custody and placed the child with paternal grandmother. - Parents divorced during proceedings; both parents sought legal custody. At disposition, LCCS withdrew its request for custody by the paternal grandmother. - A magistrate awarded legal custody to Father, a decision the trial court adopted; Mother filed objections asserting the court failed to base the custody decision on the child’s best interest. - The trial court summarily overruled Mother’s objections and entered judgment granting Father legal custody; Mother appealed to the Ninth District Court of Appeals. - On appeal, Mother argued the court did not evaluate the statutorily mandated best-interest factors and that the magistrate acted as an advocate for Father; the appellate court reviewed whether the record showed consideration of required factors. ### Issues | Issue | Plaintiff's Argument | Defendant's Argument | Held | |---|---:|---:|---:| | Whether the trial court based its legal-custody award on the child’s best interest | Mother: Court failed to apply or analyze mandatory best-interest factors required by R.C. 2151.414(D) / 3109.04(F) | Father: (implicit) Award was in child’s best interests; magistrate and trial court concluded so | Reversed and remanded: judgment does not show consideration/analysis of required best-interest factors, so appellate court cannot affirm or reweigh evidence | | Whether the magistrate abandoned neutrality and prejudiced Mother by questioning the guardian ad litem | Mother: Magistrate’s questioning showed advocacy for Father and rejection of the GAL, causing prejudice | Appellee: Issue not raised below; forfeited except for plain error | Not reached on merits: issue forfeited and its plain-error review would be tied to best-interest factual findings the court found lacking | ### Key Cases Cited * Murphy v. Reynoldsburg, 65 Ohio St.3d 356 (1992) (appellate courts must not substitute their judgment for trial courts on factual findings; outlines limits of appellate review)