13 Ohio opinions name it 1 courts 1994–2025 5 in the last five years
The cases below were cited by Ohio courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
In re V.S.green1 sentence2025In re V.S., 2017-Ohio-9136, ¶ 12 (9th Dist.). {¶17} Mother concedes that CSB proved Subsection (D)(1), and the evidence supports that prong of the dependency test. | 1 | 1 |
State v. Pearsongreen1 sentence2025Mother argues that the trial court relied on her testimony from the dispositional phase in reaching its adjudication-phase judgment. {¶49} The findings of fact that the trial court made based on mother’s testimony were: (1) that mother previously lost custody of her children for a three-year period under similar circumstances to those leading to the July 2024 dependency hearing, (2) that psychiatric medication had been prescribed for several of mother’s children, and mother had refused to give them that medication, (3) that mother uses medical marijuana to treat her PTSD, and (4) that mother’s | 1 | 1 |
State v. Wilesgreen1 sentence2025Mother argues that the trial court relied on her testimony from the dispositional phase in reaching its adjudication-phase judgment. {¶49} The findings of fact that the trial court made based on mother’s testimony were: (1) that mother previously lost custody of her children for a three-year period under similar circumstances to those leading to the July 2024 dependency hearing, (2) that psychiatric medication had been prescribed for several of mother’s children, and mother had refused to give them that medication, (3) that mother uses medical marijuana to treat her PTSD, and (4) that mother’s | 1 | 1 |
In re Burrellgreen1 sentence2023See In re Burrell, 58 Ohio St.2d 37, 39 (1979) (holding that, in a dependency analysis, “[t]he conduct of a parent is relevant * * * solely insofar as that parent’s conduct forms a part of the environment of this child”). {¶42} During her testimony, Reagan stated that she grew up in a home with domestic violence. | 1 | 1 |
In re Riddlegreen2 sentences2022Appellants contend that the trial court’s neglected and/or dependency finding is against the manifest weight of the evidence. {¶50} For ease of discussion, we first consider appellants’ assertion that the trial court’s dependency adjudication is against the manifest weight of the evidence.3 C {¶51} R.C. 2151.04(C) defines a dependent child as “any child * * * [w]hose condition or environment is such as to warrant the state, in the interests of the child, in assuming the child’s guardianship.” A dependency inquiry under R.C. 2151.04(C) “focuses exclusively on the child’s situation to determine 2022Appellants contend that the trial court’s neglected and/or dependency finding is against the manifest weight of the evidence. {¶50} For ease of discussion, we first consider appellants’ assertion that the trial court’s dependency adjudication is against the manifest weight of the evidence.3 C {¶51} R.C. 2151.04(C) defines a dependent child as “any child * * * [w]hose condition or environment is such as to warrant the state, in the interests of the child, in assuming the child’s guardianship.” A dependency inquiry under R.C. 2151.04(C) “focuses exclusively on the child’s situation to determine | 1 | 1 |
In Re Ettergreen2 sentences2020See In re Etter, 134 Ohio App.3d 484 , 731 N.E.2d 694 (1st Dist.1998). {¶25} This case does not meet the plain-error standard. 2020See In re Etter, 134 Ohio App.3d 484 , 731 N.E.2d 694 (1st Dist.1998). {¶25} This case does not meet the plain-error standard. | 1 | 1 |
In Re Allen, Unpublished Decision (6-1-2004)green1 sentence2008C.R. , 108 Ohio St.3d 369 , 2006-Ohio-1191 , 843 N.E.2d 1188 ; See also, In re Bumette, In re Waiters/Coller Children , Stark App. No. 2001CA00194, 2001-Ohio-1967 , See also, In re Allen , Delaware App. No. 03CAF08041, 2004-Ohio-2911 ; In re Nawrocki , Stark App. No. 2004-CA-0028, 2004-Ohio-4208 ; In re D.R. , 153 Ohio App.3d 156 , 2003-Ohio-2852 , 792 N.E.2d 203 . {¶ 33} The Supreme Court of Ohio made it clear in In re C.R. that once a child has been adjudicated dependent it is no longer necessary to find the parent unsuitable, since this determination had already been made at the dependency | 1 | 1 |
In re Fassingergreen2 sentences1994See In re Fassinger (1975), 42 Ohio St.2d 505 , 71 O.O.2d 503 , 330 N.E.2d 431 . 1994See In re Fassinger (1975), 42 Ohio St.2d 505 , 71 O.O.2d 503 , 330 N.E.2d 431 . | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Ohio. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
In Re Stoll
green
2 sentences2009I tend to agree with Judge Shaw's dissenting opinion in In re Stoll , 165 Ohio App.3d 226 , 2006-Ohio-346 that a parent's voluntary act of placing a child with a responsible relative should be viewed as one factor or indicator that a trial court should consider when adjudicating a dependency claim. 2009I tend to agree with Judge Shaw's dissenting opinion in In re Stoll , 165 Ohio App.3d 226 , 2006-Ohio-346 that a parent's voluntary act of placing a child with a responsible relative should be viewed as one factor or indicator that a trial court should consider when adjudicating a dependency claim. | 2 | 2009–2009 |
In re O.G.
neutral
1 sentence2023Mother did not provide any familial placement suggestions at the time of removal. [Cite as In re O.G., 2023-Ohio-4483 .] {¶5} The juvenile court appointed a Guardian ad Litem for the children. {¶6} The juvenile court held a dependency hearing on November 10, 2021. | 1 | 2023–2023 |
In Re D.R.
green
2 sentences2008C.R. , 108 Ohio St.3d 369 , 2006-Ohio-1191 , 843 N.E.2d 1188 ; See also, In re Bumette, In re Waiters/Coller Children , Stark App. No. 2001CA00194, 2001-Ohio-1967 , See also, In re Allen , Delaware App. No. 03CAF08041, 2004-Ohio-2911 ; In re Nawrocki , Stark App. No. 2004-CA-0028, 2004-Ohio-4208 ; In re D.R. , 153 Ohio App.3d 156 , 2003-Ohio-2852 , 792 N.E.2d 203 . {¶ 33} The Supreme Court of Ohio made it clear in In re C.R. that once a child has been adjudicated dependent it is no longer necessary to find the parent unsuitable, since this determination had already been made at the dependency 2008C.R. , 108 Ohio St.3d 369 , 2006-Ohio-1191 , 843 N.E.2d 1188 ; See also, In re Bumette, In re Waiters/Coller Children , Stark App. No. 2001CA00194, 2001-Ohio-1967 , See also, In re Allen , Delaware App. No. 03CAF08041, 2004-Ohio-2911 ; In re Nawrocki , Stark App. No. 2004-CA-0028, 2004-Ohio-4208 ; In re D.R. , 153 Ohio App.3d 156 , 2003-Ohio-2852 , 792 N.E.2d 203 . {¶ 33} The Supreme Court of Ohio made it clear in In re C.R. that once a child has been adjudicated dependent it is no longer necessary to find the parent unsuitable, since this determination had already been made at the dependency | 1 | 2008–2008 |
In re C.R.
green
1 sentence2008C.R. , 108 Ohio St.3d 369 , 2006-Ohio-1191 , 843 N.E.2d 1188 ; See also, In re Bumette, In re Waiters/Coller Children , Stark App. No. 2001CA00194, 2001-Ohio-1967 , See also, In re Allen , Delaware App. No. 03CAF08041, 2004-Ohio-2911 ; In re Nawrocki , Stark App. No. 2004-CA-0028, 2004-Ohio-4208 ; In re D.R. , 153 Ohio App.3d 156 , 2003-Ohio-2852 , 792 N.E.2d 203 . {¶ 33} The Supreme Court of Ohio made it clear in In re C.R. that once a child has been adjudicated dependent it is no longer necessary to find the parent unsuitable, since this determination had already been made at the dependency | 1 | 2008–2008 |
In Re Nawrocki, Unpublished Decision (8-9-2004)
neutral
1 sentence2008C.R. , 108 Ohio St.3d 369 , 2006-Ohio-1191 , 843 N.E.2d 1188 ; See also, In re Bumette, In re Waiters/Coller Children , Stark App. No. 2001CA00194, 2001-Ohio-1967 , See also, In re Allen , Delaware App. No. 03CAF08041, 2004-Ohio-2911 ; In re Nawrocki , Stark App. No. 2004-CA-0028, 2004-Ohio-4208 ; In re D.R. , 153 Ohio App.3d 156 , 2003-Ohio-2852 , 792 N.E.2d 203 . {¶ 33} The Supreme Court of Ohio made it clear in In re C.R. that once a child has been adjudicated dependent it is no longer necessary to find the parent unsuitable, since this determination had already been made at the dependency | 1 | 2008–2008 |
In re Murray
green
1 sentence2003Id. {¶ 13} While appellants cite authority indicating that alleged error arising in a dependency hearing may be raised on appeal of a subsequent grant of permanent custody, see In re Fennell , Athens App. No. 01CA45, 2002-Ohio-521 , this authority is inapplicable to the present matter. | 1 | 2003–2003 |
In Re Hall
green
1 sentence2001Upon taking the oral motion under advisement, the juvenile court determined that Appellant, as the incarcerated parent, bore the burden of proving that having the children visit him in prison was in the children's best interest pursuant to In re Hall (1989), 65 Ohio App.3d 88 . | 1 | 2001–2001 |
In Re Smith
green
1 sentence1998As previously observed, because parental rights are considered “basic” and “essential,” parents in a dependency proceeding *493 are to be given “ ‘every procedural and substantive protection the law allows.’ ” Hayes, supra, at 48 , 679 N.E.2d at 682, quoting Smith, supra, at 16 , 601 N.E.2d at 54 . | 1 | 1998–1998 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.