2 canonical passages across 2 cases, quoted by 40 opinions in total. These passages cluster together because the same opinions keep quoting them side by side — they state parts of one doctrine. The anchor passage is from Bester v. Lake County Office of Family & Children.
| # | Case | Flag | Canonical passage | Citers |
|---|---|---|---|---|
| 1 | Bester v. Lake County Office of Family & Children Anchor | green | “sufficient to show by clear and convincing evidence that the child's emotional and physical development are threatened by the respondent parent's custody.” | 37 |
| 2 | In Re ES | green | “need not wait until a child is irreversibly influenced by a deficient lifestyle such that her physical, mental, and social growth is permanently impaired before terminating the parent-child relationship.” | 3 |
A red or yellow flag on a member means the underlying case has negative treatment — for those, check the case page before relying on the passage.