In re T.G., 2018 Ohio 502

T.G., born Aug. 7, 2011, is medically fragile (cytomegalovirus, bilateral deafness, cerebral palsy, seizure disorder) and required extensive medical care and appointments.
In Dec. 2014 the agency obtained temporary custody after T.G. was hospitalized with serious injuries (lacerated liver, broken rib, healing ankle fractures, bruising); child was adjudicated abused by agreement.
The agency adopted a reunification case plan requiring parenting classes, attendance at medical appointments, stable housing/income, psychological assessment, and random drug/alcohol screens.
Mother attended only 50 of 112 visitation sessions and roughly 20–25 of 158 medical appointments; she missed the majority of required drug screens (63 of 75) and had positive tests for alcohol and one for OxyContin.
T.G. remained in the same foster home for the duration of the case; foster parents are willing to adopt and provided consistent specialized care.
The juvenile court granted permanent custody to the agency after finding T.G. had been in temporary custody for over 12 of the prior 22 months and that permanent custody was in T.G.’s best interest; mother appealed.

Issue	Appellant's Argument	Agency's Argument	Held
Whether terminating mother’s parental rights was reversible error	Mother argued poverty/transportation and that father caused the physical abuse; she contended termination was unjust	Agency argued mother failed to comply with case plan (missed visits/appointments/drug screens), and T.G. needs a legally secure placement	Court affirmed: evidence supports termination; best interest and 12-of-22-month custody prong satisfied
Whether statutory 12-of-22-month custody prong was met	Mother did not dispute	Agency established T.G. had been in temporary custody long enough	Court affirmed the prong was met
Whether grant of permanent custody was in T.G.’s best interest	Mother argued her bond and circumstance mitigated against termination	Agency pointed to foster placement stability, mother’s inconsistent participation, and child’s medical needs requiring secure placement	Court found best-interest factors favored agency (bonding, guardian ad litem recommendation, foster home stability)
Whether mother’s noncompliance was attributable to poverty/transportation	Mother claimed financial/transport barriers limited compliance	Agency demonstrated offers of transportation aid and referrals; mother still missed services and tests	Court found noncompliance was mother’s and weighed against reunification

Troxel v. Granville, 530 U.S. 57 (recognition of parental rights as fundamental)
In re C.F., 113 Ohio St.3d 73 (parental-rights framework in Ohio)
In re D.A., 113 Ohio St.3d 88 (R.C. 2151.414 two-part permanent-custody test)
In re C.W., 104 Ohio St.3d 163 (application of permanent custody statute)
In re K.H., 119 Ohio St.3d 538 (permanent custody may be necessary for child’s best interest)
Eastley v. Volkman, 132 Ohio St.3d 328 (manifest-weight standard of review)