In re C.A., 2016 Ohio 7349

C.A., born Aug. 4, 2014, was placed in temporary custody of Shelby County JFS immediately after birth because six siblings had previously been removed and parents had ongoing case-plan issues.
C.A. remained in Agency custody from August 2014 and was never returned to parents; Agency filed for permanent custody on Oct. 26, 2015 (child in custody >12 of preceding 22 months).
Father Tim Anderson participated intermittently in services and visitation; visits were suspended July 2015 after incidents of angry, threatening, or uncooperative behavior and failure to follow some provider recommendations.
Evidence at the permanent custody hearing: Anderson lacked steady employment and stable housing, had sporadic attendance in therapy (terminated by him), exhibited persistent anger and mistrust of the Agency, and had prior children removed by children services.
CASA and Agency witnesses testified C.A. was bonded to her foster family, the foster parents met her needs and sought adoption, and permanency with the Agency would be in C.A.’s best interest.
Trial court found statutory ground under R.C. 2151.414(B)(1)(d) satisfied and, after weighing the R.C. 2151.414(D) best-interest factors, terminated Anderson’s parental rights and granted permanent custody to the Agency; the appellate court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether termination of parental rights was against the manifest weight of the evidence (best-interest determination)	Anderson: court erred; evidence did not support finding termination served child’s best interest — he loved the child and would provide care if given chance	Agency: clear-and-convincing evidence supported best-interest factors (lack of parent–child bond, unstable housing/employment, anger/mental-health concerns, foster bonding and permanency needs)	Affirmed: trial court’s best-interest findings supported by competent, credible evidence and were not against the manifest weight of the evidence
Whether the trial court considered all statutory best-interest factors under R.C. 2151.414(D)	Anderson: court failed to consider all statutory criteria	Agency: court expressly addressed the primary R.C. 2151.414(D) factors and considered others where supported by record	Affirmed: court considered required factors; record supports finding under R.C. 2151.414(D) and (B)(1)(d)

In re Murray, 52 Ohio St.3d 155 (1990) (recognizes parental right to custody as a fundamental liberty interest subject to termination under appropriate circumstances)