In re T.J.W., 2014 Ohio 4419

Three children of Channe Fleischer and Adrian Wolfe—T.J.W. (born 2011), N.A.W. (born 2012), and N.M.W. (born 2012)—were involved with JCDJFS after twins tested positive for drugs at birth.
Mother admitted snorting pills before birth that may have been laced with heroin, prompting filing of dependency/abuse-neglect complaints on January 3, 2013.
JCDJFS sought adjudications of abused/neglected/dependent for the twins and dependency for T.J.W., plus temporary custody pending disposition.
Ex parte custody was granted at an informal shelter care hearing on January 3, 2013.
Adjudicatory hearing on February 21, 2013 resulted in rulings that T.J.W. was dependent and the twins were abused/neglected/dependent, with temporary custody to JCDJFS.
Disposition hearing (April 1, 2013) and Juvenile Court adoption (April 24, 2013) granted temporary custody to JCDJFS; no objections were filed by either parent.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Waiver and plain error for lack of objections	Wolfe argued there was error in the magistrate's findings.	No objections were timely raised, preserving waiver.	Waived; no plain error found.

Fearer v. Humility of Mary Health Partners, 2008-Ohio-1181 (7th Dist. 2008) (waiver and plain error considerations)
Goldfuss v. Davidson, 79 Ohio St.3d 116 (1997) (plain error standard)
In re I.T.A. and A.A., 2012-Ohio-1689 (7th Dist. 2012) (waiver rule and application)
Schade v. Carnegie Body Co., 70 Ohio St.2d 207 (1982) (standard for error preservation)
In re J.C., 2013-Ohio-2819 (11th Dist. 2013) (plain error and review standard)
State v. Barnes, 2002-Ohio-68 (Ohio Supreme Court 2002) (definition of plain error)