In re G.B., 2017 Ohio 8759

Father (D.B.) and mother had three children removed in March 2015 after findings of an unfit home, parental substance abuse, visible injuries to children, and neglect; GCCS obtained temporary custody.
Parents missed the June 2015 adjudicatory hearing; children were adjudicated neglected/dependent and case plans were established for both parents (father required substance abuse assessment/testing, stable housing, domestic-violence counseling, visitation).
Father’s last visit with the children was April 2015; he missed most scheduled visits, had outstanding warrants, was incarcerated mid‑2015, briefly entered a residential program in January 2016 but left quickly, and otherwise had sporadic contact with the caseworker.
GCCS filed for permanent custody March 4, 2016; hearings were held in August and September 2016. The children had been in foster care since removal and showed marked improvement in foster care, with strong bonds to foster parents and ongoing counseling needs.
The juvenile court awarded permanent custody to GCCS; father appealed asserting (1) lack of clear-and-convincing evidence for abandonment/best interests, (2) inadequate reasonable efforts by GCCS to reunify, and (3) abuse of discretion in denying a second extension of temporary custody.

Issue	Plaintiff's Argument (D.B.)	Defendant's Argument (GCCS)	Held
Whether evidence supports abandonment and that permanent custody is in children’s best interest	Father: Agency prevented visitation and thus statutory presumption of abandonment was rebutted; permanent custody not in best interest	GCCS: Father failed to visit for >90 days, refused scheduled visits, lacked case‑plan progress, children bonded to foster parents and improved there	Court: Statutory presumption of abandonment applied and was not rebutted; clear and convincing evidence supports permanent custody as in children’s best interest
Whether GCCS made reasonable reunification efforts	Father: Agency did not reasonably try to reunify him with children	GCCS: Made referrals (visitation, treatment), the court made reasonable‑efforts findings; father largely failed to cooperate or complete case plan	Court: GCCS made reasonable efforts; father did not substantially comply with case plan; assignment overruled
Whether juvenile court abused discretion by denying second extension of temporary custody	Father: Court should have granted additional six‑month extension to allow reunification progress	GCCS: Father had not made substantial additional progress; children needed stable, legally secure placement; statutory period limits apply	Court: No abuse of discretion; denial affirmed because father failed to show requisite substantial progress and extension not in children’s best interest

In re Estate of Haynes, 25 Ohio St.3d 101 (Ohio 1986) (defines "clear and convincing evidence" standard)
In re C.F., 113 Ohio St.3d 73 (Ohio 2007) (explains "reasonable efforts" requirement and agency obligations in child‑welfare proceedings)
Blakemore v. Blakemore, 5 Ohio St.3d 217 (Ohio 1983) (standard for abuse of discretion review)