In re J.G., 2021 Ohio 3259

Children (born 2010 and 2011) were removed after a 2015 case involving domestic violence and drug exposure; dependency adjudications followed and the Agency sought permanent custody after multiple placements and failed reunification attempts.
Mother has a lengthy history of domestic-violence incidents, criminal charges (including aggravated menacing, obstructing, disorderly conduct), episodic homelessness, and volatile, impulsive behavior that disrupted casework and supervised visits.
Mother tested positive for marijuana on virtually all submitted drug screens, declined extended inpatient substance treatment, and obtained a medical-marijuana card; she also has documented mental-health diagnoses and prior inpatient treatment as a juvenile.
Both children are special-needs with significant behavioral problems; they have improved and are bonded to their current foster-to-adopt placements.
The Agency and GAL moved for permanent custody; the juvenile court granted permanent custody to the Agency on March 18, 2021. Mother appealed only the failure to appoint a guardian ad litem (GAL) for her.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the juvenile court erred by not appointing a guardian ad litem for Mother under R.C. 2151.281 and Juv.R. 4	Mother: She "appears to be mentally incompetent" and thus required a GAL to protect her interests	Agency: Mother never appeared legally incompetent at trial; she was represented by counsel, made no GAL request, and any objection is waived except plain error; no prejudice shown	Court: No GAL required — Mother did not appear incompetent, made no request, was represented by counsel, and she showed no prejudice from lack of GAL; judgment affirmed

Goldfuss v. Davidson, 79 Ohio St.3d 116 (1997) (civil plain-error doctrine can apply; standards for noticing plain error in noncriminal cases)
In re Etter, 134 Ohio App.3d 484 (1st Dist. 1999) (discusses appointment of guardian ad litem and application of plain-error review in juvenile proceedings)