In re B.M., 2012 Ohio 4093

CSB filed complaints Sept. 22, 2011 alleging neglect/dependence due to parents' mental health and alleged domestic abuse by Father.
Mother had been admitted to a psychiatric unit and reported suicidal and homicidal thoughts; she claimed ongoing abuse by Father.
Guns were found throughout the home (20–30 rifles shotguns, loaded, no safety) raising safety concerns for the children.
Shelter care hearing appointed Mother an attorney, but she later fired counsel; court allowed withdrawal with ongoing in-court assistance from former counsel.
Adjudicatory hearing: Mother represented herself; no evidence from Mother or Father; CSB presented its case; court dismissed neglect, found dependency due to Mother's mental health, and placed children in CSB temporary custody.
Appellants appeal on counsel-related issues; dispositional hearing occurred with parents absent and former counsel available; court ultimately affirmed the disposition and noted lack of jurisdiction over some issues.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Right to counsel at adjudicatory and dispositional stages	Mother had right to court-appointed counsel at all stages.	Good cause allowed withdrawal; no obligation to appoint new counsel once pro se.	Good cause to withdraw; no error in not appointing new counsel.
Effectiveness of counsel regarding hearsay evidence	Counsel deficient for permitting uncle's hearsay statements without cross-examination.	Hearsay issue was avoided; evidence never admitted; counsel effectively protected against prejudice.	No deficient performance or prejudice; ineffective-assistance claim overruled.
Appealability of dispositional-order components (psych evaluation directive) versus final disposition	Dispositional orders affecting rights are appealable; challenge to psychological-evaluation component should be reviewable.	That aspect is interlocutory and not final for appellate review.	Court lacks jurisdiction to address the interlocutory psych-evaluation aspect; final dispositional orders remain reviewable.

In re Murray, 52 Ohio St.3d 155 (1990) (adjudication of neglect/dependence followed by temporary custody is final and appealable)
In re C.H., 162 Ohio St.3d 602 (2005) (good cause to withdraw counsel when continued representation is not feasible)
In re Rachal G., 2003-Ohio-1041 (2003) (circumstances showing good cause for withdrawal; waiver possible when parent fails to cooperate)
In re T.K., 2008-Ohio-1687 (2008) (pro se representation and withdrawal considerations in juvenile proceedings)
Harness v. Harness, 143 Ohio App.3d 669 (2001) (hearsay and admissibility issues; appellate treatment of certain trial rulings)