Background - Mother appealed juvenile-court award of legal custody of her two children (K.C., b. 2011; A.G., b. 2015) to the paternal great-aunt and -uncle after children were adjudicated neglected and dependent and placed with relatives. - LCCS removed the children after reports of parental drug use, domestic violence, mental-health concerns, eviction, and a prior sex-offender registration failure by Father; agency implemented safety plans and a case plan for Mother addressing substance abuse, domestic violence, mental health, housing, visitation, and cooperation with the caseworker. - Mother entered and left multiple treatment programs, was terminated from Family Drug Court for leaving LCADA, later completed one program but tested positive for marijuana and cocaine in mid-2016, and had been sober only about a month at the custody hearing. - Mother attended fewer than half of in-person visits, moved to Tennessee shortly before the final hearing, had unstable housing and uncertain employment prospects, and had a recent domestic-violence incident and a bipolar diagnosis she minimized. - The children had lived with Aunt and Uncle for about 11 months, were reported to be thriving (medical, developmental, school adjustment), and the guardian ad litem recommended legal custody to Aunt and Uncle. - The magistrate and juvenile court found (1) LCCS made reasonable efforts to reunify, (2) awarding legal custody to Aunt and Uncle was in the children’s best interests, and (3) denied Mother’s request for a six-month extension of temporary custody; this appeal followed. ### Issues | Issue | Mother’s Argument | LCCS / Aunt & Uncle’s Argument | Held | |---|---:|---|---| | Whether legal custody award was against the manifest weight of the evidence / not in children’s best interests | Mother claimed she made sufficient case-plan progress and a six-month extension would permit reunification | Agency and relatives argued Mother had not remedied substance abuse, domestic violence, mental-health, housing, or stability concerns; children are settled with caregivers | Court affirmed: award to Aunt and Uncle supported by preponderance; not against manifest weight; extension would not likely lead to reunification | | Whether LCCS failed to make reasonable efforts to reunify | Mother argued agency didn’t follow up with Tennessee providers after her move | LCCS cited extensive referrals, safety plans, family team meetings, home visits, and services offered; Mother’s choices and inconsistent participation frustrated reunification | Court affirmed: agency made reasonable efforts; Mother’s conduct—moving without coordination and short-lived treatment—undercut her argument | | Whether juvenile court erred in considering GAL report because GAL investigation was inadequate | Mother argued GAL did not conduct a proper investigation and thus reporting should be excluded | GAL testified to monthly visits, observations of visits, contacts with parties and caseworker, and child-focused inquiry; other evidence independently supported findings | Court held Mother forfeited the issue by not objecting below; even under plain-error review, GAL report consideration was not reversible error | ### Key Cases Cited Eastley v. Volkman, 132 Ohio St.3d 328 (Ohio 2012) (standard for manifest-weight review and deference to factfinder) In re C.F., 113 Ohio St.3d 73 (Ohio 2007) (definition and scope of agency’s “reasonable efforts” obligation) Goldfuss v. Davidson, 79 Ohio St.3d 116 (Ohio 1997) (civil plain-error standard for exceptional circumstances) State v. White, 142 Ohio St.3d 277 (Ohio 2015) (criminal plain-error standard requiring different outcome to prevent manifest miscarriage of justice)