Court Filings

The Ohio Tenth District Court of Appeals affirmed the juvenile court’s decision granting permanent custody of two-year-old A.S. to Franklin County Children Services (FCCS), thereby terminating the parental rights of mother L.S. After FCCS filed for permanent custody following nearly two years of involvement because of mother’s mental-health crises, housing instability, and inconsistent engagement with case-plan requirements, the juvenile court found permanent custody was in the child’s best interest. The appeals court held the trial court did not abuse its discretion in denying a day-of-trial continuance and that mother failed to show she received ineffective assistance of counsel or that any alleged deficiency prejudiced her case.

The Ohio Sixth District Court of Appeals affirmed the juvenile court’s September 9, 2025 decision awarding Lucas County Children Services (LCCS) permanent custody of the minor E.D.-P. The child had been adjudicated dependent and temporarily placed with paternal relatives in Texas; LCCS later sought permanent custody. The appellate court held the juvenile court properly found by clear and convincing evidence that R.C. 2151.414(E)(11) applied because Mother had previously had parental rights involuntarily terminated to a sibling and failed to prove she could now provide a legally secure, adequate permanent placement. The court found Mother remained cohabiting and dependent with the child’s father, who showed no engagement in parenting, and the record supported the juvenile court’s findings that reunification was not feasible within a reasonable time.

The Fourth Court of Appeals affirmed the trial court’s May 2024 order terminating Mother C.A.’s parental rights to infant G.M.L. The Department of Family and Protective Services had removed the children after repeated concerns about Mother’s substance use, hazardous home conditions, and a domestic-violence incident. The appeals court held that the Department gave fair notice and presented clear-and-convincing evidence that it made reasonable reunification efforts and that a continuing danger remained in Mother’s home, supporting termination and appointment of the Department as permanent managing conservator.

The First District Court of Appeals affirmed the juvenile court’s denial of a mother’s 2024 motion to regain legal custody of her two children, B.B. and R.W. The juvenile court and magistrate found the mother failed to prove changed circumstances since the 2018 legal-custody disposition to father. The court concluded the evidence (photos, medical summaries, and testimony) did not substantiate abuse or medical neglect by father nor show missed medical care produced harmful consequences sufficient to overcome the statutory presumption of permanency for juvenile-court custody orders.

The Ohio Court of Appeals affirmed a juvenile court judgment awarding permanent custody of infant J.J. to Lucas County Children’s Services (LCCS). The agency filed an original permanent-custody complaint two days after J.J.’s birth based on parents’ extensive prior child-welfare history, unresolved substance-use, housing, and domestic-violence concerns, and prior involuntary termination of parental rights to siblings. The trial court found by clear and convincing evidence that the parents had not rebutted the presumption in R.C. 2151.414(E)(11) and that awarding permanent custody to LCCS was in J.J.’s best interest, so parental rights were terminated.

The First District of Texas affirmed the trial court’s order terminating the mother’s parental rights to her nine-year-old twins and awarding sole managing conservatorship to the Department of Family and Protective Services (DFPS). The court reviewed an accelerated appeal from a bench trial and found the evidence legally and factually sufficient to show the mother knowingly placed or allowed the children to remain in endangering conditions (unsanitary, no utilities, presence of feces and urine, reports of physical abuse) and that termination was in the children’s best interest. The court relied on the children’s improved stability and care in their foster home, the mother’s criminal history, repeated positive drug tests, failure to complete services, and prior dangerous living conditions to support its decision.

The First Court of Appeals of Texas affirmed a trial court's modification of a 2016 custody order that named Carolyn Pena sole managing conservator and restricted George E. Saldana’s visitation. Saldana, representing himself, argued the trial was void because a recusal motion was pending, he lacked adequate notice of the trial, and his arrest and detention around trial made the proceedings unfair. The court held that a “tertiary recusal” statute allowed the trial judge to proceed, that the record shows Saldana had actual notice more than 45 days before trial, and that the trial court did not abuse its discretion in denying a new trial despite the arrest and security incidents.

The First District of Texas affirmed the divorce decree in Ada U. Oguamanam v. Tony Oguamanam. Ada argued on appeal that she was harmed because the trial court signed findings of fact and conclusions of law that she did not receive notice of, preventing her from timely requesting additional findings. The court held that Ada failed to show the required injury — she could have requested additional findings after learning of them or sought abatement but did not — and that the proposed additional findings she identified were largely evidentiary or unnecessary to decide the controlling issues. The judgment is affirmed.

The Court of Appeal affirmed the family court’s orders vacating a default judgment in a marital dissolution case and denying the petitioner’s request for a statement of decision, then remanded for further proceedings. The court held the default judgment exceeded the relief requested in the form petition because the petition left property division items as “to be determined,” so the entry of a default awarding specific property violated the respondent’s due process right to notice. The court also concluded Family Code set-aside provisions and Code of Civil Procedure section 580 both apply, found the record supported mistake/lack of notice, and directed amendment of the petition and an opportunity to answer.

The Athens County Juvenile Court’s grant of permanent custody of two children to Athens County Children Services was affirmed on appeal. The children had been in agency custody for more than 12 of a consecutive 22-month period. The parents argued the award was against the manifest weight of the evidence and that the agency failed to make reasonable reunification efforts. The court held prior trial-court orders had already found reasonable efforts and that clear-and-convincing evidence supported that permanent custody served the children’s best interests given parental mental-health issues, unresolved interpersonal violence between the parents, the daughter’s refusal to reunify, and the children’s need for stability.

The First District Court of Appeals affirmed the trial court’s adoption of a magistrate’s decision modifying parenting time for the parties’ minor son C.K., and partially granting a contempt finding and awards. The court held that modification was in C.K.’s best interest based on evidence that he was triggered by mother and preferred to reside primarily with father; the court found father in contempt only for failing to pay child support, not for other alleged violations. The court also affirmed allocation of guardian ad litem fees (split roughly two-thirds to father) and a small $500 attorney-fee award to mother.

The First District Court of Appeals affirmed the juvenile court’s rulings awarding legal custody of J.L. to the maternal grandmother. The appeal arose from a custody petition filed by the grandmother after the child’s mother died and subsequent interim-custody orders. The appellate court found challenges to the interim emergency orders moot because the juvenile court later made a final custody determination. The court upheld the juvenile court’s finding that the father was an unsuitable parent based on abandonment and detriment to the child, and it affirmed denial of the father’s Civ.R. 60(B) motion for relief for failure to plead operative facts warranting relief.

The Ohio Court of Appeals affirmed a juvenile court’s October 30, 2025 judgment granting legal custody of two children, K.M.H. and D.J.L.H., to their maternal grandparents. The grandparents had filed motions for custody after longstanding involvement with the children; a magistrate heard evidence in 2021, issued a decision in 2024, and after a status hearing in 2025 issued a new decision adopted by the trial court. The appellate court held the juvenile court had subject-matter jurisdiction, found the October 30, 2025 order final and appealable, and concluded no plain error invalidated the custody award because the magistrate expressly found awarding custody to the mother would be detrimental and considered the children’s best interests.

The Ohio Court of Appeals affirmed the juvenile court’s grant of permanent custody of B.H. to the Montgomery County Department of Job and Family Services (MCCS). The child entered agency custody shortly after birth and, despite periods of compliance, Mother repeatedly relapsed into substance abuse, missed services, lost housing, and failed to maintain regular contact or visitation. The court found MCCS had custody for more than 12 of 22 consecutive months, made reasonable reunification efforts, and that permanent custody was in the child’s best interest given the need for a stable, legally secure placement with foster parents willing to adopt.

The Court of Appeal affirmed a postjudgment order in a divorce case that awarded the wife $12,500 in attorney’s fees (rather than about $49,000 she sought) after she prevailed on a dispute over the family home. The trial court reduced the requested fees based on the parties’ limited finances, overlitigation, and the reasonableness of the fees. The appellate court held the family law court did not err: when a marital settlement agreement contains a prevailing-party fee clause, the trial court may still consider Family Code factors (including ability to pay) in fixing the amount of fees, and it did not abuse its discretion here.

The Eighth District Court of Appeals affirmed the juvenile court’s decision awarding legal custody and residence of minor S.B. to her mother. Father, appearing pro se, had sought shared parenting and custody but the trial court and guardian ad litem concluded the parents could not communicate effectively or set aside personal disputes for the child’s benefit. The appellate court found the trial court did not abuse its discretion in determining shared parenting was not feasible and in designating Mother as the residential parent after considering statutory best-interest factors and trial testimony.

The Ohio Eighth District Court of Appeals affirmed the juvenile court’s decision denying the father’s motion to modify parental rights and granting in part the mother’s modification requests. The dispute involved a 2016 parenting agreement naming mother residential custodian and the child’s wishes to live with father and play football at a different high school. The trial court found no material change in circumstances to justify changing custody to father but modified certain logistical terms (travel notice, single phone, sharing activity costs) as in the child’s best interest. The court also properly handled the guardian ad litem (GAL) report and fee requests.