In re S.R., 2017 Ohio 8412

In January 2015 HCJFS was alerted to deplorable living conditions and Mother’s mental-health concerns; S.R. was temporarily placed with maternal great-grandparents and then returned to Mother.
Mother was later charged with child endangering and drug-paraphernalia offenses; the magistrate found S.R. at imminent risk and placed her in foster care; in May 2015 the juvenile court adjudicated S.R. abused, neglected, and dependent.
HCJFS obtained extensions of temporary custody; in March 2017 HCJFS moved to terminate temporary custody and award legal custody to S.R.’s paternal great-grandparents; the guardian ad litem supported the request.
Mother argued the magistrate/trial court failed to adequately analyze S.R.’s best interest and improperly weighed the criminal history of Mother’s ex‑boyfriend.
The record showed S.R. had unmet medical needs when removed, Mother had inconsistent mental‑health treatment and drug-related incidents (missed screens, a positive test, occasions of smelling of marijuana), and paternal great‑grandparents had established an approved, stable, supportive placement with visitation facilitation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the juvenile court’s order was final and appealable	Mother implied procedural defects rendered the order nonfinal	Court: the magistrate’s decision was adopted and entered as judgment during objection period and dispositional language was in the judgment entry	Order was final and this court has jurisdiction
Whether the trial court abused its discretion in awarding legal custody to paternal great‑grandparents under the child's best‑interest standard	Mother: court failed to thoroughly weigh best‑interest factors and overemphasized ex‑boyfriend’s criminal history	HCJFS and GAL: record supports best‑interest finding (child’s needs, Mother’s instability, secure placement by great‑grandparents)	No abuse of discretion; legal custody to great‑grandparents affirmed

Pembaur v. Leis, 1 Ohio St.3d 89, 437 N.E.2d 1199 (1982) (defines abuse‑of‑discretion as more than error of law or judgment; implies unreasonable, arbitrary, or unconscionable conduct)