In re T.T., 2017 Ohio 485

T.T., born May 2016, was placed in foster care at birth; mother (M.T.) already had six other children and none were in her custody. Four were with relatives and two were in the agency’s permanent custody.
Lucas County Children Services filed for dependency and sought permanent custody on May 9, 2016; temporary custody was granted after a shelter-care hearing.
At adjudication (July 11, 2016) the parties stipulated that T.T. was dependent; a permanent-custody hearing occurred August 8, 2016.
The agency relied on mother’s long history of failing to complete case plans and mental-health treatment, previous involuntary terminations of parental rights to siblings, and the child’s need for a stable, permanent placement.
The guardian ad litem recommended permanent custody to the agency, citing home-condition and caregiving concerns; foster parents were willing to adopt.
The juvenile court awarded Lucas County Children Services permanent custody; appellate counsel filed an Anders brief seeking leave to withdraw as no non-frivolous issues were found.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court’s grant of permanent custody was against the manifest weight of the evidence	M.T.: permanent-custody decision was against manifest weight; she now engaged in mental-health services and had housing/resources	Agency: M.T. has repeated failure to complete case plans, chronic, impairing mental illness, prior terminations, and child requires permanency	Affirmed: trial court’s findings supported by clear and convincing evidence; permanent custody proper

Anders v. California, 386 U.S. 738 (1967) (procedure for counsel to seek withdrawal when appeal is frivolous)
State v. Duncan, 57 Ohio App.2d 93 (1978) (Ohio procedure following Anders)
Cross v. Ledford, 161 Ohio St. 469 (1959) (definition of clear and convincing evidence)
In re William S., 75 Ohio St.3d 95 (1996) (clarifies standard for terminating parental rights and awarding permanent custody)