permanency hearing (Ohio) · Go Syfert
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permanency hearing in Ohio

7 Ohio opinions name it 1 courts 2008–2026 4 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.

Followed or applied (4)

CaseFollowedCited
In Re A.D., Unpublished Decision (10-13-2005)green
ohioctapp · 2005 · cited in 1 Ohio opinions naming this issue, 2026–2026
1 sentence

2026See also In re A.D., 2005-Ohio-5441, ¶ 8 (8th Dist.) (finding that by failing to object to the trial court’s use of the report and failing to request to cross-examine the GAL, appellant had waived all but plain error on appeal.). {¶ 45} Here, the GAL was not at the permanency hearing because she had withdrawn from the case after submitting her final report.

11
In re A.K.green
ohioctapp · 2012 · cited in 1 Ohio opinions naming this issue, 2026–2026
1 sentence

2026See e.g., In re A.K., 2012-Ohio-4430, at ¶ 29 (9th Dist.) (“Because the trial court failed to consider any evidence from a guardian ad litem or the children directly, the children were denied their right to have a voice at this dispositional hearing that determined their permanent placement.”); In re F.R., 2008-Ohio-6570 (12th Dist.); In re A.G.B., 2007-Ohio-4753, at ¶ 19 (4th Dist.); In the Matter Of: Strowbridge, 1982 WL 3565 , at *1 (4th Dist.

11
In Re A.G.B.green
ohioctapp · 2007 · cited in 1 Ohio opinions naming this issue, 2026–2026
1 sentence

2026See e.g., In re A.K., 2012-Ohio-4430, at ¶ 29 (9th Dist.) (“Because the trial court failed to consider any evidence from a guardian ad litem or the children directly, the children were denied their right to have a voice at this dispositional hearing that determined their permanent placement.”); In re F.R., 2008-Ohio-6570 (12th Dist.); In re A.G.B., 2007-Ohio-4753, at ¶ 19 (4th Dist.); In the Matter Of: Strowbridge, 1982 WL 3565 , at *1 (4th Dist.

11
In re D.D.green
ohioctapp · 2023 · cited in 1 Ohio opinions naming this issue, 2025–2025
1 sentence

2025“To the extent that the trial court relies on R.C. 2151.414(E)(1) at a permanency hearing, the court must examine the ‘reasonable case planning and diligent efforts by the agency to assist the parents’ when considering whether the child cannot or should not be placed with the parent within a reasonable time.” C.F., 2007-Ohio-1104 , at ¶ 42; In re D.D., 2023-Ohio-4147, ¶ 23 (10th Dist.).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Ohio. Read the followed side critically anyway.

Also cited on this issue (4)

CaseCitedYears
In re C.F. green
ohio · 2007
2 sentences

2024Stark County, Case Nos. 2023CA00123 & 2023CA00124 5 {¶ 13} As held by the Supreme Court of Ohio in In re C.F., 113 Ohio St.3d 73 , 2007-Ohio-1104 , 862 N.E.2d 816 , ¶ 42-43: To the extent that the trial court relies on R.C. 2151.414(E)(1) at a permanency hearing, the court must examine the "reasonable case planning and diligent efforts by the agency to assist the parents" when considering whether the child cannot or should not be placed with the parent within a reasonable time.

2022In the case relied upon by Mother, In re C.F., 113 Ohio St.3d 73 , 2007-Ohio-1104 , the Ohio Supreme Court stated: “To the extent that the trial court relies on R.C. 2151.414(E)(1) at a permanency hearing, the court must examine the ‘reasonable case planning and diligent efforts by the agency to assist the parents’ when considering whether the child cannot or should not be placed with the parent within a reasonable time.” In re C.F. at ¶ 42.

32008–2024
In Re F.R., Ca2008-07-070 (12-15-2008) green
ohioctapp · 2008
1 sentence

2026See e.g., In re A.K., 2012-Ohio-4430, at ¶ 29 (9th Dist.) (“Because the trial court failed to consider any evidence from a guardian ad litem or the children directly, the children were denied their right to have a voice at this dispositional hearing that determined their permanent placement.”); In re F.R., 2008-Ohio-6570 (12th Dist.); In re A.G.B., 2007-Ohio-4753, at ¶ 19 (4th Dist.); In the Matter Of: Strowbridge, 1982 WL 3565 , at *1 (4th Dist.

12026–2026
In Re Alexander, Unpublished Decision (12-19-2006) neutral
ohioctapp · 2006
1 sentence

2016No. 06-CA-834, 2006-Ohio-7083 , the juvenile court stated that "DJFS does not have a duty to reunite the child with a family member unless the family member is a party to the case." Father argues that this was an incorrect statement of law.

12016–2016
In the Matter of A.C., Unpublished Decision (10-18-2004) green
ohioctapp · 2004
1 sentence

2008Therefore, `[b]y its plain terms, the statute does not apply to motions for permanent custody brought pursuant to *Page 11 R.C. 2151.413 , or to hearings held on such motions pursuant to R.C. 2151.414 .' In re: A.C. , supra, 2004-Ohio-5531 , 2004 WL 2340127 , ¶ 30." In re: CF , supra 113 Ohio St.3d at 80 , 2007-Ohio-1104 at ¶ 41 , 862 N.E.2d at 823 . {¶ 31} "To the extent that the trial court relies on R.C. 2151.414 (E)(1) at a permanency hearing, the court must examine the `reasonable case planning and diligent efforts by the agency to assist the parents' when considering whether the child ca

12008–2008

Statutes the citing opinions construe

OH § Ohio Rev. Code § 2151.414 (5) OH § Ohio Rev. Code § 2151.353 (3) OH § Ohio Rev. Code § 2151.413 (3) OH § Ohio Rev. Code § 2151.419 (3)

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.

Where else courts name it

NY 174 (1999–2026) OR 115 (2002–2026) CA 86 (1995–2026) IA 48 (1989–2026) UT 47 (1999–2025) IL 38 (1999–2026) TX 35 (2002–2026) PA 33 (2000–2025) AL 20 (2002–2017) WY 20 (2010–2026) NJ 16 (2000–2022) AZ 16 (2000–2026) VT 13 (2001–2024) DC 11 (2001–2019) IN 11 (2003–2020) FL 9 (1978–2021) CO 8 (2000–2024) NM 8 (2004–2019) OH 7 (2008–2026) MO 7 (2015–2024) AK 7 (2001–2018) LA 6 (1993–2016) MT 6 (2002–2015) WV 6 (2009–2023) NC 4 (2000–2018) ND 3 (2010–2010) DE 3 (2015–2019) ID 3 (2010–2022) CT 3 (2004–2010) MD 2 (1996–2021) NE 2 (2016–2019) MA 2 (2013–2014) KY 2 (2001–2021)

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.

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