Skip to content Skip to main navigation Skip to footer
Ohio Case Law

In re G.J., et al., 2025-Ohio-4854

Case Information

Court: Court of Appeals of Ohio, Eighth Appellate District, County of Cuyahoga
Date: 2025-10-23
Citation: 2025-Ohio-4854
Read the Opinion

Summary

Summary: The appellate court affirmed a juvenile court’s decision granting permanent custody of two minor children to the Cuyahoga County Division of Children and Family Services, finding clear and convincing evidence supported that custody was in the children’s best interests due to the Father’s alleged failure to meet parental obligations.

Key Holdings

  • A parent’s failure to regularly visit or communicate with children can support a finding of lack of commitment under R.C. 2151.414(E)(4)
  • Failure to obtain suitable housing and verify income demonstrates inability to provide for children’s basic needs under R.C. 2151.414(E)(14)
  • Sporadic or no visitation despite reasonable opportunities supports a finding of neglect under R.C. 2151.414(E)(3)
  • Permanent custody may be granted when both statutory prongs under R.C. 2151.414(B) and (D) are met by clear and convincing evidence
  • A juvenile court’s discretion in permanent custody decisions is afforded significant deference on appeal

More Information

This case involves an appeal by the Father from a decision of the Cuyahoga County Court of Common Pleas, Juvenile Division, granting permanent custody of his twin minor children to CCDCFS. The children, born in 2021, had been in the agency’s temporary custody since January 2023 following their removal from the Mother’s home due to alleged chronic substance abuse and mental health issues. The initial complaint was refiled after being dismissed for procedural reasons. The refiled complaint alleged that the children were neglected and that Father had allegedly not supported or maintained contact with them.

The Father was ordered to complete a case plan involving parenting classes, obtaining suitable housing, proving income, visitation, and compliance with random drug and alcohol testing. Testimony from a CCDCFS caseworker, family advocate, and the guardian ad litem revealed that Father’s visitation was inconsistent and often missed or late. Despite being provided opportunities, he allegedly had not visited the children since November 2024. His housing was found unsuitable due to its temporary nature and lack of lease inclusion. He failed to verify income despite claiming self-employment and did not comply with all alcohol testing requirements.

The juvenile court found that the statutory requirements under R.C. 2151.414 were met, specifically noting the Father’s lack of consistent support, stable housing, and verified income. The court determined that returning the children to Father was not feasible within a reasonable time and that permanent custody was in the children’s best interest. The appellate court, applying a manifest weight of the evidence standard, upheld this decision, citing the trial court’s superior position to assess credibility and factual context.

Ultimately, the appellate court found no reversible error, concluding that the juvenile court’s judgment was supported by competent, credible evidence and aligned with the statutory framework. The decision reinforces the principle that the best interest of the child is paramount and parental rights may be terminated where a parent fails to demonstrate commitment or capability to meet basic parental duties.