PCC hearing in Ohio

2026J.R., 2024-Ohio-5619, at ¶ 8 (10th Dist.), citing In re J.C., 2011-Ohio-715 , ¶ 46 (10th Dist.).

2025There is nothing in the record indicating that the regular mail notices to No. 24AP-414 11 mother were returned as undeliverable.3 See J.M., 2025-Ohio-2410, at ¶ 22 (10th Dist.) (“[T]he record readily shows that Mother was sent notice of the May 13, 2024 hearing on the PCC motion, to wit: on March 20, 2024, an original copy of the hearing notice for May 13, 2024, at 10:00 a.m., was filed on the docket and mailed to Mother at her last known physical address.

2024See In re K.J., 2018-Ohio-471 , 107 N.E.3d 50, ¶ 21 (10th Dist.) (“by the time of the PCC hearing, the children had been in FCCS’s custody for more than two years, and granting a continuance on the day of the hearing would have presented an inconvenience to opposing counsel * * * as well as prolonging the accomplishment of the ultimate goal of establishing permanency for the children”); In re E.C., 12th Dist.

2024See In re K.J., 2018-Ohio-471 , 107 N.E.3d 50, ¶ 21 (10th Dist.) (“by the time of the PCC hearing, the children had been in FCCS’s custody for more than two years, and granting a continuance on the day of the hearing would have presented an inconvenience to opposing counsel * * * as well as prolonging the accomplishment of the ultimate goal of establishing permanency for the children”); In re E.C., 12th Dist.

2024Butler No. CA2016-01- 014, 2016-Ohio-2774, ¶ 14 (“[i]n light of the duration of the case, E.C.’s need for permanency, Father’s failure to complete any of the services recommended by the agency, and Father’s lack of involvement with E.C., we find the juvenile court did not abuse its discretion in denying Father’s motion for a continuance”).

2024Butler No. CA2016-01- 014, 2016-Ohio-2774, ¶ 14 (“[i]n light of the duration of the case, E.C.’s need for permanency, Father’s failure to complete any of the services recommended by the agency, and Father’s lack of involvement with E.C., we find the juvenile court did not abuse its discretion in denying Father’s motion for a continuance”).

2024No. 08AP- 186, 2009-Ohio-438, ¶ 5-6 (trial court did not abuse its discretion in denying request for continuance where the request is made the day of the hearing after parent failed to appear and counsel is unable to give a reason for the parent’s absence or explain the parent’s whereabouts). {¶ 16} Pursuant to R.C. 2151.414(A)(2), the trial court is to hold the PCC hearing no later than 120 days after the agency files the PCC motion except for “good cause” shown for a reasonable continuance.

2024No. 08AP- 186, 2009-Ohio-438, ¶ 5-6 (trial court did not abuse its discretion in denying request for continuance where the request is made the day of the hearing after parent failed to appear and counsel is unable to give a reason for the parent’s absence or explain the parent’s whereabouts). {¶ 16} Pursuant to R.C. 2151.414(A)(2), the trial court is to hold the PCC hearing no later than 120 days after the agency files the PCC motion except for “good cause” shown for a reasonable continuance.

2020No. 03AP-348, 2003-Ohio-5344, ¶ 19 (finding that substantial completion of case plan requirements does not preclude a grant of permanent custody to a social services agency). {¶ 32} In the present case, the main issue that prevented mother from successfully challenging the PCC motion was her lack of stable and suitable housing.

2001See State v. Seiber (1990), 56 Ohio St.3d 4 , 17 ; see, also, In re Baker, supra (where mother and attorney were voluntarily absent at a PCC hearing and could not cross-examine a witness, mother cannot claim error on appeal because she induced any error); In the Matter of Butler (Mar. 4, 1996), Stark App. No. 1995CA00070, unreported (mother was estopped from raising ineffective assistance of counsel argument on appeal for her counsel's withdrawal at PCC dispositional hearing when it was caused solely by mother's voluntary absence and failure to communicate with her attorney regarding her case)

2001See State v. Seiber (1990), 56 Ohio St.3d 4 , 17 ; see, also, In re Baker, supra (where mother and attorney were voluntarily absent at a PCC hearing and could not cross-examine a witness, mother cannot claim error on appeal because she induced any error); In the Matter of Butler (Mar. 4, 1996), Stark App. No. 1995CA00070, unreported (mother was estopped from raising ineffective assistance of counsel argument on appeal for her counsel's withdrawal at PCC dispositional hearing when it was caused solely by mother's voluntary absence and failure to communicate with her attorney regarding her case)

2001See Hall v. Solid Corp. (Dec. 3, 1985), Franklin App. No. 85AP-576, unreported; see, also, Bennett v. Bennett (1993), 86 Ohio App.3d 343 , 347 ; In re Donnelly (Mar. 31, 2000), Ashtabula App. No. 98-A-0054, unreported (trial court violated an absent mother's due process rights by allowing her appointed attorney to withdraw from a PCC case at the final hearing; court should have either required the attorney to proceed because appellant had the right to be represented or, in the alternative, granted a continuance); In re Bowman (Sept. 8, 1992), Stark App. No. CA-8853, unreported (abuse of discre

2001See Hall v. Solid Corp. (Dec. 3, 1985), Franklin App. No. 85AP-576, unreported; see, also, Bennett v. Bennett (1993), 86 Ohio App.3d 343 , 347 ; In re Donnelly (Mar. 31, 2000), Ashtabula App. No. 98-A-0054, unreported (trial court violated an absent mother's due process rights by allowing her appointed attorney to withdraw from a PCC case at the final hearing; court should have either required the attorney to proceed because appellant had the right to be represented or, in the alternative, granted a continuance); In re Bowman (Sept. 8, 1992), Stark App. No. CA-8853, unreported (abuse of discre