In re G.F., 2014 Ohio 2580

In 2011 Middletown police found G.F., C.F., and T.F. wandering outside at night; A.R. was at appellant's home with a bag of marijuana.
Appellant was convicted of child endangerment; BCDJFS filed four complaints, and the children were removed and placed in foster care.
All four children were adjudicated dependent by stipulation.
BCDJFS prepared four case plans aimed at reunification, but appellant failed to consistently obtain mental health treatment, failed drug tests, lacked stable housing, failed to address T.F.'s medical needs, and did not consistently attend visitation.
In September 2012, BCDJFS moved for permanent custody; after hearings, the magistrate granted permanent custody to BCDJFS; the juvenile court overruled appellant's objections.
Appellant M.R. appeals raising two assignments of error; the court held permanency to be in the children's best interests and that the record supported the decision.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Best interests of the children for permanent custody	M.R. argues not in children’s best interests	BCDJFS argues best interests support permanent custody	Permanent custody to agency affirmed based on best interests.
Effect of counsel/GAL changes on trial prejudice	Appellant alleges prejudice from withdrawal of counsel and split GAL roles	No prejudice proven; appointments timely and proper	No reversible error; procedures proper and in children's best interests.

Santosky v. Kramer, 455 U.S. 745 (U.S. (1982)) (clear and convincing standard prior to termination of parental rights)
In re Starkey, 150 Ohio App.3d 612 ((7th Dist. 2002)) (review of permanent custody requires substantial credible evidence)
In re E.B., 2010-Ohio-1122 (12th Dist. Warren Nos. CA2009-10-139, CA2009-11-146) (best interests and statutory factors guide custody decision)
In re Williams, 101 Ohio St.3d 398 (2004-Ohio-1500) (counsel rights for juveniles and role distinctions in GAL/attorney)