Cluster 4859481

Accordingly, Father has waived all but plain error for appeal on those issues. 7 {¶ 21} “‘The plain error doctrine permits correction of judicial proceedings when error is clearly apparent on the face of the record and is prejudicial to the appellant.’” Schutz v. Schutz, 2017-Ohio-695, ¶ 44 (2d Dist.), quoting Reichert v. Ingersoll, 18 Ohio St.3d 220, 223 (1985). “‘In civil cases, the plain error doctrine is not favored and may only be applied in the extremely rare case invo…

Id.; D.E., 2021-Ohio-524 at ¶ 92 (noting a juvenile court is not bound by a guardian ad litem’s recommendation).

Sup.R. 48.03(D) provides, in its relevant part that, “[u]nless specifically relieved by the court,” the GAL shall “[o]bserve the child with each parent, foster parent, guardian or physical custodian”; “[i]nterview the parties . . . and other significant individuals who may have relevant knowledge regarding the issues of the case”; “[i]nterview relevant . . . medical and mental health providers . . . and obtain copies of relevant records”; and “[r]equest that the court order …

"It is not possible to determine whether the ICWA applies or does not apply if the proper inquiry pursuant to 25 C.F.R. 23.107 is not made." In re D.E., 2021-Ohio-524, ¶ 60 (10th Dist.) (reversing and remanding to conduct ICWA inquiries 2. {¶ a} In its answer brief, the Agency argues that Mother only provided transcripts of the permanent custody hearing, but the trial court could have made the inquiry at another hearing in the case, therefore, without these other transcripts…

See also In re D.E., 2021-Ohio-524, ¶ 92 (10th Dist.) (stating that “the duty of the GAL is to provide the court with information and recommendations regarding the children’s best interest”).