In re T.W., 2017 Ohio 8268

WCCS removed infant T.W. after birth (Nov. 22, 2015) when he tested positive for cocaine and exhibited serious developmental and medical conditions requiring ongoing specialized care.
WCCS placed T.W. in temporary custody; juvenile court adjudicated him neglected and dependent and ordered continued temporary custody in April 2016.
Mother entered and partially engaged with multiple substance‑abuse and mental‑health programs, provided both negative and positive drug screens, repeatedly disappeared for extended periods, missed visits and failed to complete case‑plan objectives (including parenting classes and stable housing/employment verification).
A second putative father was identified but expressly refused involvement; Mother’s counsel did not move for genetic testing of him.
WCCS moved for permanent custody (Feb. 2017); Mother moved for a six‑month extension of temporary custody (Mar. 2017). After a May 2017 hearing, the juvenile court denied the extension and granted WCCS permanent custody. Mother appealed.

Issue	Mother’s Argument	WCCS’s Argument	Held
Ineffective assistance of counsel for not seeking paternity testing of the second putative father	Counsel was deficient for failing to move for genetic testing; a positive result might have produced placement options and justified an extension	Counsel’s decision was reasonable; testing might not identify father, and even if it did the putative father refused to participate or provide placement; delay would harm child’s need for permanence	Not ineffective: no deficient performance or prejudice; testing unlikely to change result and delay would contravene child’s interest in permanence
Denial of motion to extend temporary custody under R.C. 2151.415(D) (six‑month extension)	Extension would allow time for paternity testing and potential placement with putative father’s family; delay would be minimal	Mother made no significant case‑plan progress in 15 months; speculation about an uninterested putative father’s family does not show reasonable cause for reunification or placement	No abuse of discretion denying extension: Mother failed to show significant case‑plan progress or reasonable cause that child would be reunified or permanently placed within extension; child’s need for stability weighed against speculative delay

Strickland v. Washington, 466 U.S. 668 (1984) (two‑part standard for ineffective assistance of counsel: deficient performance and prejudice)
State v. Morris, 132 Ohio St.3d 337 (2012) (abuse‑of‑discretion review described as deferential)