In re I.A., 2013 Ohio 360

CSB filed on Oct. 22, 2010 alleging I.A. was neglected/dependent due to Mother’s heroin and prescription-drug addiction, and unstable housing/mental health; I.A. removed and placed in CSB temporarily.
Mother entered treatment but relapsed, leaving I.A. with a relative who could not provide long-term care; mental health issues and instability persisted.
CSB moved for permanent custody on Apr. 3, 2012; Mother sought legal custody to maternal grandparents.
Mother continually tested positive for benzodiazepines and other drugs; she failed to address mental health, parenting, housing, and employment needs.
Hearing designated I.A. in CSB custody for more than 12 of the prior 22 months; foster placement deemed best for I.A.; maternal grandparents’ legal custody request denied.
Guardian ad litem and caseworker described a stable, loving foster home; grandparents had limited interaction with I.A. and delayed visiting until late in the case.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court’s denial of legal custody to the maternal grandparents was against the manifest weight of the evidence	Mother argues grandparents should have legal custody	CSB argues permanent custody to CSB serves I.A.’s best interests	Yes; court affirmed, approving permanent custody to CSB over grandparents.

In re William S., 75 Ohio St.3d 95 (Ohio 1996) (permanent custody factors and best-interests standard)
In re T-G.M., 9th Dist. No. 25858, 2011-Ohio-3940 (9th Dist. 2011) (best interests review under R.C. 2151.414(D))
In re C.M., 2003-Ohio-5040 (9th Dist. 2003) (time in custody and parental rights considerations)