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Ohio Case Law

In re Z.L., et al., 2025-Ohio-4851

Case Information

Court: Court of Appeals of Ohio, Eighth Appellate District, County of Cuyahoga
Date: 2025-10-23
Citation: 2025-Ohio-4851
Read the Opinion

Summary

Summary: The Court of Appeals of Ohio affirmed the juvenile court’s decision to grant permanent custody of three minor children to Cuyahoga County Department of Children and Family Services and to terminate the parental rights of their father, who appealed the decision. The court held that despite completing required services, the father failed to sufficiently remedy the conditions leading to the children’s removal and did not demonstrate the ability to provide a safe and stable environment.

Key Holdings

  • A parent’s completion of case plan services does not preclude a grant of permanent custody when the parent fails to demonstrate actual benefit or behavioral change
  • A child’s extended time in agency custody combined with repeated adjudications of abuse or dependency supports a grant of permanent custody
  • Domestic violence between parents and a failure to comply with substance use and mental health treatment are grounds for denying reunification
  • Courts must determine best interests of the child based on statutory factors including stability and the likelihood of recurrence of abuse or neglect

More Information

This case involved a father’s appeal from the juvenile court’s decision awarding permanent custody of his three children to the county agency and terminating his parental rights. The family’s history included multiple prior involvements with child protective services due to domestic violence and concerns over the parents’ mental health and substance use. In the current matter, the children were removed after another domestic violence incident involving the parents in the presence of the children.

Although the father completed numerous case plan objectives—including domestic violence, parenting, and substance abuse programs—the juvenile court found he had not actually benefited from the services. Evidence showed continued incidents of domestic violence with the mother, failures to maintain sobriety, and parenting behaviors that included verbal aggression and inappropriate interactions. The children expressed fear of the father, and multiple professionals testified about the lack of meaningful progress.

The court determined that under Ohio Revised Code R.C. 2151.414, permanent custody was in the best interest of the children. The children had been in agency custody for more than twelve months in a twenty-two-month period and had been adjudicated abused or dependent on at least three occasions. The father failed to demonstrate a sustained ability to provide a stable home and continued to expose the children to harmful conditions.

The appellate court reviewed the juvenile court’s findings for manifest weight of the evidence and found ample support for the decision. The trial court had appropriately considered statutory best-interest factors and made credibility determinations that favored the agency’s witnesses. The appellate court emphasized that completing services is not equivalent to correcting the underlying issues that necessitated removal. As a result, the appellate court affirmed the termination of parental rights and the award of permanent custody to the agency.