In re J.F., 2016 Ohio 1285

J.F., born March 23, 2014, tested positive for cocaine and opiates at birth; mother voluntarily relinquished her rights and did not appeal. Older siblings were previously removed for parental drug use and domestic violence.
Wayne County CSB filed for custody; both parents stipulated that J.F. was an abused child and the child was placed in CSB temporary custody under an adopted case plan.
Father (Jesse F.) was represented by court‑appointed counsel throughout; he repeatedly failed to comply with case‑plan requirements (no visits, missed drug testing, poor contact, no counseling progress) and later was convicted of drug offenses and child endangering and sentenced to three years’ incarceration.
At a permanent‑custody hearing while incarcerated, Father signed a written parental stipulation to permanent custody and orally confirmed to the trial judge that his surrender of parental rights was voluntary, knowing, and without promises or threats.
Two weeks later Father requested to appeal; appellate counsel filed an Anders brief asserting the appeal was frivolous and sought permission to withdraw.
The Ninth District independently reviewed the record, found no merit to Father’s claims that he was coerced or did not understand his rights, accepted the Anders submission, granted counsel leave to withdraw, and affirmed the termination of paternal rights.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Father’s written and oral stipulation to permanent custody was voluntary, knowing, and intelligent	Father asserted he was pressured, lied to, and did not understand his rights	Trial judge and CSB contended Father knowingly signed the stipulation, was questioned on the record, and acknowledged waiver of rights	Court held the record shows a voluntary, knowing, intelligent waiver after oral colloquy and signed stipulation; no basis to overturn
Whether appellate counsel properly filed an Anders brief and may withdraw	Father claimed denial of rights and sought appeal	Appellate counsel argued there were no meritorious issues and appeal was frivolous under Anders	Court agreed the appeal was frivolous, granted withdrawal, and affirmed judgment

Anders v. California, 386 U.S. 738 (1967) (counsel may file a brief stating appeal is frivolous and seek permission to withdraw; court must conduct independent review)
Elmer v. Lucas Cty. Children Servs. Bd., 36 Ohio App.3d 241 (1987) (trial court must ensure parental admissions are voluntary and made with understanding of rights)