(A)(1) In any proceeding in which a child has been adjudicated an unruly, abused, neglected, or dependent child, on the application of a party, or on the court's own motion, the court may make an order restraining or otherwise controlling the conduct of any parent, guardian, or other custodian in the relationship of that individual to the child if the court finds that an order of that type is necessary to do either of the following:
(a) Control any conduct or relationship that will be detrimental or harmful to the child.
(b) Control any conduct or relationship that will tend to defeat the execution of the order of disposition made or to be made.
(2) The court shall give due notice of the application or motion under division (A) of this section, the grounds for the application or motion, and an opportunity to be heard to the person against whom an order under this division is directed. The order may include a requirement that the child's parent, guardian, or other custodian enter into a recognizance with sufficient surety, conditioned upon the faithful discharge of any conditions or control required by the court.
(B) The authority to make an order under division (A) of this section and any order made under that authority is in addition to the authority to make an order pursuant to division (C)(2) of section 2151.354 or division (A)(7)(b) of section 2152.19 of the Revised Code and to any order made under either division.
(C) A person's failure to comply with any order made by the court under this section is contempt of court under Chapter 2705. of the Revised Code.
Notes of Decisions
Cited in 15
cases (10 in the last 5 years), 1988–2025 · leading case: In Re Pieper Child., 619 N.E.2d 1059 (Ohio Ct. App. 1993).
In Re Pieper Child., 619 N.E.2d 1059 (Ohio Ct. App. 1993). · cites it 3ד” In any proceeding wherein a child has been adjudged dependent, R.C. 2151.359 permits the'trial court to make an order restraining or controlling the conduct of a parent in the relationship of such individual to the child if the court finds that such an order is necessary to…”
In re I.E., 2020 Ohio 3477 (Ohio Ct. App. 2020). · cites it 2ד” The trial court rejected Mother’s argument, stating that R.C. 2151.359(A)(1) granted the court authority to preclude Mother from residing with I.”
In re W.W., 2024 Ohio 878 (Ohio Ct. App. 2024). · cites it 3ד{¶54} Additionally, R.C. 2151.359(A)(1) vests trial courts with “ ‘broad authority * * * to make orders controlling or restraining the parents of children adjudged dependent.”
Cox v. Court of Common Pleas of Franklin Cnty., 537 N.E.2d 721 (Ohio Ct. App. 1988). · cites it 3דThe respondent court and the guardian ad litem maintain that R.C. 2151.359 authorizes the juvenile court to issue and enforce its order against relator.”
In re M.B., 2023 Ohio 1804 (Ohio Ct. App. 2023). “was over, both the caseworker and the guardian ad litem, as well as other witnesses, testified that they believed that Mother and D.”
In Re Sarah H., 621 N.E.2d 545 (Ohio Ct. App. 1993). · cites it 6דThe board submits that the court need not find that appellant committed the abuse; rather, the court’s order is consistent with R.C. 2151.359, which permits the juvenile court to restrain or otherwise control a parent’s conduct if such is necessary to control any conduct or…”
In re M.B., 2012 Ohio 5428 (Ohio Ct. App. 2012). “” R.C. 2151.359(A)(1). Accordingly, Father is not guaranteed visitation with his son, but visitation remains an issue to be considered and ruled upon by the juvenile court.”
In re L.S., 2022 Ohio 3281 (Ohio Ct. App. 2022). “{¶30} Under R.C. 2151.359(A)(1)(a), the trial court explicitly retained the authority to “[c]ontrol any [parental] conduct or relationship that will be detrimental or harmful to the child[,]” which includes the authority to limit or even prohibit parental visitation with a child…”
In re K.B., 2021 Ohio 3273 (Ohio Ct. App. 2021). “” R.C. 2151.359(A)(1). In other words, Father is not necessarily entitled to visitation with K.”
In re C.T., 2022 Ohio 3464 (Ohio Ct. App. 2022). “Under R.C. 2151.359(A)(1), the trial court explicitly retained the authority to “[c]ontrol any [parental] conduct or relationship that will be detrimental or harmful to the child[,]” which includes the authority to limit or even prohibit parental visitation with a child placed…”
In re S.S., 2022 Ohio 520 (Ohio Ct. App. 2022). “C. 2151.011(B)(48). Moreover, Chapter 2151 does not provide a definitive test or set of criteria to apply in determining whether, and on what terms, to grant visitation rights to the noncustodial parents in proceedings incident to a disposition pursuant to R.”
In re C.P., 2023 Ohio 1350 (Ohio Ct. App. 2023). “Moreover, R.C. 2151.359(A)(1) allows the juvenile court to limit any person’s interactions with a child if those restrictions are necessary for the welfare of the child.”
In re I.E., 2020 Ohio 3477 (Ohio Ct. App. 2020). “” The trial court rejected Mother’s argument, stating that R.C. 2151.359(A)(1) granted the court authority to preclude Mother from residing with I.”
In re M.B., 2012 Ohio 5428 (Ohio Ct. App. 2012). “” R.C. 2151.359(A)(1). Accordingly, Father is not guaranteed visitation with his son, but visitation remains an issue to be considered and ruled upon by the juvenile court.”
In re K.B., 2021 Ohio 3273 (Ohio Ct. App. 2021). “” R.C. 2151.359(A)(1). In other words, Father is not necessarily entitled to visitation with K.”
In re C.T., 2022 Ohio 3464 (Ohio Ct. App. 2022). “Under R.C. 2151.359(A)(1), the trial court explicitly retained the authority to “[c]ontrol any [parental] conduct or relationship that will be detrimental or harmful to the child[,]” which includes the authority to limit or even prohibit parental visitation with a child placed…”
In re S.S., 2022 Ohio 520 (Ohio Ct. App. 2022). “C. 2151.011(B)(48). Moreover, Chapter 2151 does not provide a definitive test or set of criteria to apply in determining whether, and on what terms, to grant visitation rights to the noncustodial parents in proceedings incident to a disposition pursuant to R.”
— Ohio Rev. Code § 2151.359(A)(1)(a) — 5 cases
In re W.W., 2024 Ohio 878 (Ohio Ct. App. 2024). “{¶54} Additionally, R.C. 2151.359(A)(1) vests trial courts with “ ‘broad authority * * * to make orders controlling or restraining the parents of children adjudged dependent.”
In re M.B., 2023 Ohio 1804 (Ohio Ct. App. 2023). “was over, both the caseworker and the guardian ad litem, as well as other witnesses, testified that they believed that Mother and D.”
In re L.S., 2022 Ohio 3281 (Ohio Ct. App. 2022). “{¶30} Under R.C. 2151.359(A)(1)(a), the trial court explicitly retained the authority to “[c]ontrol any [parental] conduct or relationship that will be detrimental or harmful to the child[,]” which includes the authority to limit or even prohibit parental visitation with a child…”
Annotations are extracted automatically from the opinions in the
Syfert caselaw corpus and ranked by authority, recency, and
treatment. Dots show Syfertize treatment of the citing case itself.