In re J.B.
2025 Ohio 2135
Ohio Ct. App.2025Background
- Hamilton County Department of Job and Family Services (HCJFS) was granted permanent custody of J.B., a minor, after previously being awarded custody of J.B.'s older siblings due to parental issues.
- The parents, Mother and Father, have a history of domestic violence, mental health concerns, and inconsistent engagement with services and visitation.
- The initial complaint in 2022 alleged dependency due to domestic violence; a subsequent complaint was filed after procedural deadlines lapsed.
- HCJFS presented evidence of the parents’ repeated failure to remedy prior problems, including periods of abandonment and persistent unsafe conditions.
- The trial court granted permanent custody to HCJFS, finding clear and convincing evidence that returning J.B. to the parents would not be in the child’s best interest.
- On appeal, both parents challenged the sufficiency and weight of the evidence supporting the juvenile court’s ruling.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the juvenile court's decision was based on insufficient evidence | Parents argued that evidence was not clear and convincing; disputed factual findings regarding domestic violence and commitment | HCJFS cited continued domestic violence, lack of visitation, and prior failures; argued statutory requirements were met | Court held evidence was sufficient and met clear and convincing standard |
| Whether the judgment was against the manifest weight of the evidence | Parents claimed their explanations (fabricated accusations, stable housing, etc.) were credible and reflected parental fitness | HCJFS maintained that documentary evidence and testimony of ongoing issues outweighed parents’ explanations | Court found the parents’ explanations not credible and the judgment was not against the weight of evidence |
| Whether HCJFS made adequate efforts to reunify the family | Parents argued lack of services limited their ability to remedy problems | HCJFS noted it was relieved of reasonable efforts due to prior terminations and ongoing patterns of unaddressed issues | Court found services provided were adequate under the law, given circumstances |
| Whether awarding permanent custody to HCJFS was in J.B.'s best interest | Mother argued she was capable of providing a stable, safe environment | HCJFS, supported by Guardian, asserted continued exposure to risk and abandonment showed otherwise | Court found permanent custody to HCJFS best served J.B.'s interests |
Key Cases Cited
- In re W.W., 2011-Ohio-4912 (reviewed sufficient evidence standard for child custody)
- In re K.H., 2024-Ohio-5292 (set standard for awarding permanent custody under Ohio law)
- In re Z.C., 2023-Ohio-4703 (defined clear and convincing evidence in juvenile custody context)
- In re A.B., 2015-Ohio-3247 (outlined standards for sufficiency and weight of evidence in custody decisions)
- In re G.K., 2008-Ohio-5442 (evaluated parental commitment through visitation patterns)