In re J.F., 2023 Ohio 4244

James born July 15, 2020; Butler County JFS obtained emergency custody July 17, 2020 and he was adjudicated dependent August 19, 2020.
Mother has a long history of serious mental‑health problems (history of hospitalizations and prior diagnoses); allegations she stopped medication and exhibited delusional thinking throughout the case.
Reunification plan required mental‑health treatment, medication compliance, psychological assessment, and participation in parenting (DLS) services; Mother sporadically engaged, missed visits, and stopped visiting entirely in Jan. 2023.
Father did not seek custody and supported the foster family/adoption; Mother’s parents repeatedly refused full home studies and no relative placement materialized.
Agency moved for permanent custody March 2022; magistrate and juvenile court found (1) permanent custody was in the child’s best interest and (2) the child had been in agency custody 12+ of 22 months. Mother appealed, arguing she remediated conditions and the agency failed to search relatives. Court affirmed.

Issue	Mother’s Argument	Agency’s Argument	Held
Whether grant of permanent custody was supported by clear and convincing evidence and not against the manifest weight of the evidence (best‑interest prong)	Mother: She remediated her mental‑health issues, has a safe home, is bonded to the child, and can parent appropriately.	Agency: Mother continued to show delusions, inconsistent treatment history, failed to complete recommended steps in a timely way, stopped visits, and foster family can provide stable adoption‑ready placement.	Court: Held for Agency — credibility and weight favored evidence of ongoing serious mental‑health issues, lack of completed home study, disrupted visitation, and child’s need for legally secure placement; best‑interest factors favored permanent custody to the Agency.
Whether the Agency failed to demonstrate reasonable efforts to locate relatives for placement (procedural/placement issue)	Mother: Agency did not present testimony proving reasonable relative search; hence permanent custody was improper.	Agency: Agency conducted relative searches (letters, Accurint searches); no relatives sought placement; statute does not require relative‑first placement before permanent custody.	Court: Declined to consider Mother’s cursory/undeveloped argument (App.R.16); noted record shows searches were performed and no relatives came forward; held issue does not reverse the judgment.

Eastley v. Volkman, 972 N.E.2d 517 (Ohio 2012) (articulates manifest‑weight review standard and deference to factfinder on witness credibility)