In re R/G Children, 2021 Ohio 839

Mother’s children S.R. (b. 2015) and K.G. (b. 2017) were removed and placed in HCJFS temporary custody in 2017–2018 and placed together in the same foster home.
The juvenile-court case plan prioritized reunification but required mother and maternal grandmother to engage in individual and joint therapy (TIP) and parenting services; both were repeatedly asked to participate in children’s therapeutic treatment.
Mother attended therapy inconsistently and ceased attending TIP sessions; grandmother attended almost no TIP sessions and had little or no bond with K.G.
S.R. developed significant mental-health diagnoses (PTSD, reactive attachment disorder, intermittent explosive disorder); both children made therapeutic progress in foster care after visits with mother were suspended.
HCJFS moved for permanent custody; grandmother filed for custody. A magistrate awarded permanent custody to HCJFS and denied grandmother’s petition; the juvenile court overruled objections and the appellate court affirmed.

Issue	Mother’s Argument	Grandmother’s Argument	Held
Whether clear-and-convincing evidence supports awarding permanent custody to HCJFS (best-interest determination under R.C. 2151.414)	Challenged sufficiency/weight of evidence that permanent custody was in children’s best interest	Argued she could provide custody and that HCJFS’s permanent-custody award was erroneous	Court held evidence supported best-interest finding: children needed a legally secure placement; foster parents were bonded and engaged in therapy; permanent custody to HCJFS affirmed
Whether juvenile court erred in denying grandmother’s custody petition	(Mother joined challenge)	Grandmother argued she could meet children’s needs and would continue therapy	Court found grandmother failed to engage in required therapeutic services, lacked relationship with K.G., and was not a credible alternative; custody petition denied

In re K.H., 895 N.E.2d 809 (Ohio 2008) (definition and required showing for clear-and-convincing evidence)