In re K.T., 2015 Ohio 3543

Juvenile complaints filed May 20, 2014; court granted LCDJFS emergency temporary custody of three children (born 2003, 2007, 2011) and appointed a guardian ad litem.
Adjudicatory hearings produced testimony from a child psychiatrist, social workers, a Family Pride case manager, and the mother.
Two older children (H.W.T. and E.T.) have serious behavioral problems, receive psychiatric care and medication, and exhibit violent threats and conduct toward family and others.
Parents kept multiple unsecured firearms in the home, refused safes/locks, and admitted a gun was kept under the mother’s pillow; children knew how to access the parents’ bedroom where guns were stored.
Incidents included a child threatening to take a gun to school, father pulling a gun during a domestic argument in front of a caseworker, physical violence among children and toward the mother, and police having been called to the home.
Magistrate found the children dependent under R.C. 2151.04(C); juvenile court adopted that decision and granted LCDJFS protective supervision. Mother appealed only the dependency finding.

Issue	Plaintiff's Argument (Mother)	Defendant's Argument (LCDJFS)	Held
Whether children are "dependent" under R.C. 2151.04(C)	Evidence insufficient; children in treatment and medicated; no proof home environment endangered them	Parents’ conduct and home conditions created dangerous environment warranting state guardianship	Court affirmed dependency finding: clear and convincing evidence supported intervention

In re Savchuk, 180 Ohio App.3d 349 (11th Dist. 2008) (describes applying criminal manifest-weight standard in juvenile abuse/neglect/dependency appeals)
State v. Martin, 20 Ohio App.3d 172 (1st Dist. 1983) (sets forth factors for manifest-weight review)
In re Holcomb, 18 Ohio St.3d 361 (Ohio 1985) (explains clear-and-convincing standard in juvenile proceedings)
State v. Thompkins, 78 Ohio St.3d 380 (Ohio 1997) (clarifies sufficiency as legal standard of review)