Ohio Rev. Code » Chapter 2151
Ohio Revised Code

Ohio Rev. Code § 2151.419 (2026)

Court's determination as to whether agency made reasonable efforts to prevent removal or to return child safely home

✓ current as of May 2026
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Effective:
June 20, 2014
Latest Legislation:
House Bill 130 - 130th General Assembly
PDF:
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(A)(1) Except as provided in division (A)(2) of this section, at any hearing held pursuant to section 2151.28, division (E) of section 2151.31, or section 2151.314, 2151.33, or 2151.353 of the Revised Code at which the court removes a child from the child's home or continues the removal of a child from the child's home, the court shall determine whether the public children services agency or private child placing agency that filed the complaint in the case, removed the child from home, has custody of the child, or will be given custody of the child has made reasonable efforts to prevent the removal of the child from the child's home, to eliminate the continued removal of the child from the child's home, or to make it possible for the child to return safely home. The agency shall have the burden of proving that it has made those reasonable efforts. If the agency removed the child from home during an emergency in which the child could not safely remain at home and the agency did not have prior contact with the child, the court is not prohibited, solely because the agency did not make reasonable efforts during the emergency to prevent the removal of the child, from determining that the agency made those reasonable efforts. In determining whether reasonable efforts were made, the child's health and safety shall be paramount.

(2) If any of the following apply, the court shall make a determination that the agency is not required to make reasonable efforts to prevent the removal of the child from the child's home, eliminate the continued removal of the child from the child's home, and return the child to the child's home:

(a) The parent from whom the child was removed has been convicted of or pleaded guilty to one of the following:

(i) An offense under section 2903.01, 2903.02, or 2903.03 of the Revised Code or under an existing or former law of this state, any other state, or the United States that is substantially equivalent to an offense described in those sections and the victim of the offense was a sibling of the child or the victim was another child who lived in the parent's household at the time of the offense;

(ii) An offense under section 2903.11, 2903.12, or 2903.13 of the Revised Code or under an existing or former law of this state, any other state, or the United States that is substantially equivalent to an offense described in those sections and the victim of the offense is the child, a sibling of the child, or another child who lived in the parent's household at the time of the offense;

(iii) An offense under division (B)(2) of section 2919.22 of the Revised Code or under an existing or former law of this state, any other state, or the United States that is substantially equivalent to the offense described in that section and the child, a sibling of the child, or another child who lived in the parent's household at the time of the offense is the victim of the offense;

(iv) An offense under section 2907.02, 2907.03, 2907.04, 2907.05, or 2907.06 of the Revised Code or under an existing or former law of this state, any other state, or the United States that is substantially equivalent to an offense described in those sections and the victim of the offense is the child, a sibling of the child, or another child who lived in the parent's household at the time of the offense;

(v) An offense under section 2905.32, 2907.21, or 2907.22 of the Revised Code or under an existing or former law of this state, any other state, or the United States that is substantially equivalent to the offense described in those sections and the victim of the offense is the child, a sibling of the child, or another child who lived in the parent's household at the time of the offense;

(vi) A conspiracy or attempt to commit, or complicity in committing, an offense described in division (A)(2)(a)(i), (iv), or (v) of this section.

(b) The parent from whom the child was removed has repeatedly withheld medical treatment or food from the child when the parent has the means to provide the treatment or food. If the parent has withheld medical treatment in order to treat the physical or mental illness or defect of the child by spiritual means through prayer alone, in accordance with the tenets of a recognized religious body, the court or agency shall comply with the requirements of division (A)(1) of this section.

(c) The parent from whom the child was removed has placed the child at substantial risk of harm two or more times due to alcohol or drug abuse and has rejected treatment two or more times or refused to participate in further treatment two or more times after a case plan issued pursuant to section 2151.412 of the Revised Code requiring treatment of the parent was journalized as part of a dispositional order issued with respect to the child or an order was issued by any other court requiring such treatment of the parent.

(d) The parent from whom the child was removed has abandoned the child.

(e) The parent from whom the child was removed has had parental rights involuntarily terminated with respect to a sibling of the child pursuant to section 2151.353, 2151.414, or 2151.415 of the Revised Code or under an existing or former law of this state, any other state, or the United States that is substantially equivalent to those sections.

(3) At any hearing in which the court determines whether to return a child to the child's home, the court may issue an order that returns the child in situations in which the conditions described in divisions (A)(2)(a) to (e) of this section are present.

(B)(1) A court that is required to make a determination as described in division (A)(1) or (2) of this section shall issue written findings of fact setting forth the reasons supporting its determination. If the court makes a written determination under division (A)(1) of this section, it shall briefly describe in the findings of fact the relevant services provided by the agency to the family of the child and why those services did not prevent the removal of the child from the child's home or enable the child to return safely home.

(2) If a court issues an order that returns the child to the child's home in situations in which division (A)(2)(a), (b), (c), (d), or (e) of this section applies, the court shall issue written findings of fact setting forth the reasons supporting its determination.

(C) If the court makes a determination pursuant to division (A)(2) of this section, the court shall conduct a review hearing pursuant to section 2151.417 of the Revised Code to approve a permanency plan with respect to the child, unless the court issues an order returning the child home pursuant to division (A)(3) of this section. The hearing to approve the permanency plan may be held immediately following the court's determination pursuant to division (A)(2) of this section and shall be held no later than thirty days following that determination.
Notes of Decisions
Cited in 507 cases (239 in the last 5 years), 1991–2026 · leading case: In re C.F., 113 Ohio St. 3d 73 (Ohio 2007).
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In re C.F., 113 Ohio St. 3d 73 (Ohio 2007). · cites it 25× “31(A)(3)(b), 1 and that before removing them, it had made reasonable efforts pursuant to R.C. 2151.419 to prevent their removal from the home, to eliminate the need for their continued removal, or to make it possible for them to return home.”
In re C.B.C., 2016 Ohio 916 (Ohio Ct. App. 2016). · cites it 12× “” However, the reasonable efforts statute, R.C. 2151.419, does not use the phrase “reunify the family.”
In re L.G., 2022 Ohio 529 (Ohio Ct. App. 2022). · cites it 15× “In each of its journal entries, the magistrate included the following reasonable- efforts findings: FINDING WHETHER REASONABLE EFFORTS WERE MADE BY AGENCY (ORC §2151.419) The Court further finds that reasonable efforts were made to prevent the removal of the child from the home,…”
In re J.H., 2016 Ohio 640 (Ohio Ct. App. 2016). · cites it 11× “Reasonable Efforts {¶ 28} Mother and father argue the agency did not use reasonable efforts to reunify the family and the juvenile court erred in refusing to allow evidence to be introduced at the permanent custody hearing relevant to the agency's reasonable efforts.”
In re B.B.C., 2024 Ohio 588 (Ohio Ct. App. 2024). · cites it 10× “Father contends that the juvenile court failed to make the findings of fact required by R.C. 2151.419. We have previously addressed this issue, where we explained: R.”
In re S.H., 2020 Ohio 3499 (Ohio Ct. App. 2020). · cites it 7× “Initially, they assert that BCCS failed to make reasonable efforts as required by R.C. 2151.419. Next, they argue that the juvenile court's decision to grant permanent custody to BCCS was not supported by sufficient evidence and was against the manifest weight of the evidence.”
In re T.S., 2017 Ohio 482 (Ohio Ct. App. 2017). · cites it 6× “In support of her reasonable-efforts argument, Mother relies on R.C. 2151.419(A)(1), which provides: (A)(1) Except as provided in division (A)(2) of this section, at any 1We fully addressed the issue of T.”
In re S.R., 2014 Ohio 2749 (Ohio Ct. App. 2014). · cites it 9× “See R.C. 2151.419. The “reasonable efforts” requirement of R.”
In re G.L.S., 2018 Ohio 1606 (Ohio Ct. App. 2018). · cites it 6× “5 MOTHER’S ASSIGNMENT OF ERROR I THE TRIAL COURT VIOLATED R.C. 2151.419 AND MOTHER’S RIGHTS TO DUE PROCESS WHEN IT ISSUED A REASONABLE EFFORTS BYPASS WITHOUT NOTICE AS TO WHEN IT WOULD BE CONSIDERED, WITHOUT GIVING MOTHER AN OPPORTUNITY TO PRESENT A DEFENSE, AND WITHOUT ISSUING…”
In Re Starkey, 782 N.E.2d 665 (Ohio Ct. App. 2002). · cites it 4× “419(A)(1), at a hearing held where the court removes a child from his home, the court shall determine whether the agency has made reasonable efforts to prevent the removal, or to eliminate continued removal, or to make it possible for the child to return home.”
In re K.W., 925 N.E.2d 181 (Ohio Ct. App. 2010). · cites it 14× “” MCCS relied on this provision in its motion to bypass reunification efforts, and the trial court agreed that such efforts were not required in this case.”
In re M.S., 2023 Ohio 1558 (Ohio Ct. App. 2023). · cites it 4× “FATHER’S ASSIGNMENT OF ERROR II THE TRIAL COURT ABUSED ITS DISCRETION AND COMMITTED PLAIN AND REVERSIBLE ERROR WHEN IT GRANTED PERMANENT CUSTODY TO [CSB] WITH A FINDING THAT THERE WAS CLEAR AND CONVINCING EVIDENCE THAT [CSB] PROVIDED REASONABLE REUNIFICATION EFFORTS PURSUANT TO…”
Show all 507 citing cases →
— Ohio Rev. Code § 2151.419(2)(d) — 1 case
In re A.L., 2015 Ohio 3735 (Ohio Ct. App. 2015).
— Ohio Rev. Code § 2151.419(A) — 55 cases
In re C.B.C., 2016 Ohio 916 (Ohio Ct. App. 2016). “” However, the reasonable efforts statute, R.C. 2151.419, does not use the phrase “reunify the family.”
In re C.F., 113 Ohio St. 3d 73 (Ohio 2007). “31(A)(3)(b), 1 and that before removing them, it had made reasonable efforts pursuant to R.C. 2151.419 to prevent their removal from the home, to eliminate the need for their continued removal, or to make it possible for them to return home.”
In re M.S., 2023 Ohio 1558 (Ohio Ct. App. 2023). “FATHER’S ASSIGNMENT OF ERROR II THE TRIAL COURT ABUSED ITS DISCRETION AND COMMITTED PLAIN AND REVERSIBLE ERROR WHEN IT GRANTED PERMANENT CUSTODY TO [CSB] WITH A FINDING THAT THERE WAS CLEAR AND CONVINCING EVIDENCE THAT [CSB] PROVIDED REASONABLE REUNIFICATION EFFORTS PURSUANT TO…”
In re N.R., 2021 Ohio 1589 (Ohio Ct. App. 2021).
In re L.G., 2022 Ohio 529 (Ohio Ct. App. 2022). “In each of its journal entries, the magistrate included the following reasonable- efforts findings: FINDING WHETHER REASONABLE EFFORTS WERE MADE BY AGENCY (ORC §2151.419) The Court further finds that reasonable efforts were made to prevent the removal of the child from the home,…”
— Ohio Rev. Code § 2151.419(A)(1) — 269 cases
In re C.F., 113 Ohio St. 3d 73 (Ohio 2007). “31(A)(3)(b), 1 and that before removing them, it had made reasonable efforts pursuant to R.C. 2151.419 to prevent their removal from the home, to eliminate the need for their continued removal, or to make it possible for them to return home.”
In re L.G., 2022 Ohio 529 (Ohio Ct. App. 2022). “In each of its journal entries, the magistrate included the following reasonable- efforts findings: FINDING WHETHER REASONABLE EFFORTS WERE MADE BY AGENCY (ORC §2151.419) The Court further finds that reasonable efforts were made to prevent the removal of the child from the home,…”
In re C.B.C., 2016 Ohio 916 (Ohio Ct. App. 2016). “” However, the reasonable efforts statute, R.C. 2151.419, does not use the phrase “reunify the family.”
In Re B.C., 2014 Ohio 4558 (Ohio 2014).
In re K.M.S., 2017 Ohio 142 (Ohio Ct. App. 2017).
— Ohio Rev. Code § 2151.419(A)(2) — 50 cases
In re C.F., 113 Ohio St. 3d 73 (Ohio 2007). “31(A)(3)(b), 1 and that before removing them, it had made reasonable efforts pursuant to R.C. 2151.419 to prevent their removal from the home, to eliminate the need for their continued removal, or to make it possible for them to return home.”
In re T.S., 2017 Ohio 482 (Ohio Ct. App. 2017). “In support of her reasonable-efforts argument, Mother relies on R.C. 2151.419(A)(1), which provides: (A)(1) Except as provided in division (A)(2) of this section, at any 1We fully addressed the issue of T.”
In re S.R., 2014 Ohio 2749 (Ohio Ct. App. 2014). “See R.C. 2151.419. The “reasonable efforts” requirement of R.”
In re C.B.C., 2016 Ohio 916 (Ohio Ct. App. 2016). “” However, the reasonable efforts statute, R.C. 2151.419, does not use the phrase “reunify the family.”
In re K.W., 925 N.E.2d 181 (Ohio Ct. App. 2010). “” MCCS relied on this provision in its motion to bypass reunification efforts, and the trial court agreed that such efforts were not required in this case.”
— Ohio Rev. Code § 2151.419(A)(2)(3) — 2 cases
In re A.A., 2016 Ohio 2992 (Ohio Ct. App. 2016).
In re S.W., 2023 Ohio 118 (Ohio Ct. App. 2023).
— Ohio Rev. Code § 2151.419(A)(2)(a) — 3 cases
In re R.S., 2017 Ohio 2835 (Ohio Ct. App. 2017).
In re T.P., 2015 Ohio 3448 (Ohio Ct. App. 2015).
In re J.L.S., 2026 Ohio 1312 (Ohio Ct. App. 2026).
— Ohio Rev. Code § 2151.419(A)(2)(a)(iii) — 3 cases
In re V.W., 2022 Ohio 2487 (Ohio Ct. App. 2022).
In re R.S., 2017 Ohio 2835 (Ohio Ct. App. 2017).
In re S.W., 2018 Ohio 1672 (Ohio Ct. App. 2018).
— Ohio Rev. Code § 2151.419(A)(2)(a)(iv) — 1 case
In re R.M., 2021 Ohio 324 (Ohio Ct. App. 2021).
— Ohio Rev. Code § 2151.419(A)(2)(b) — 3 cases
In re M.A.P., 2013 Ohio 655 (Ohio Ct. App. 2013).
In re J.B., 2020 Ohio 3351 (Ohio Ct. App. 2020).
In re B.R.H., 2025 Ohio 5181 (Ohio Ct. App. 2025).
— Ohio Rev. Code § 2151.419(A)(2)(b)(d) — 1 case
In re S.U., 2014 Ohio 5748 (Ohio Ct. App. 2014).
— Ohio Rev. Code § 2151.419(A)(2)(d) — 14 cases
In re T.P., 2016 Ohio 72 (Ohio Ct. App. 2016).
In Re Starkey, 782 N.E.2d 665 (Ohio Ct. App. 2002). “419(A)(1), at a hearing held where the court removes a child from his home, the court shall determine whether the agency has made reasonable efforts to prevent the removal, or to eliminate continued removal, or to make it possible for the child to return home.”
In re D.M., 2016 Ohio 1450 (Ohio Ct. App. 2016).
In re L.M., 2017 Ohio 610 (Ohio Ct. App. 2017).
In re V.W., 2022 Ohio 2487 (Ohio Ct. App. 2022).
— Ohio Rev. Code § 2151.419(A)(2)(e) — 46 cases
In re G.L.S., 2018 Ohio 1606 (Ohio Ct. App. 2018). “5 MOTHER’S ASSIGNMENT OF ERROR I THE TRIAL COURT VIOLATED R.C. 2151.419 AND MOTHER’S RIGHTS TO DUE PROCESS WHEN IT ISSUED A REASONABLE EFFORTS BYPASS WITHOUT NOTICE AS TO WHEN IT WOULD BE CONSIDERED, WITHOUT GIVING MOTHER AN OPPORTUNITY TO PRESENT A DEFENSE, AND WITHOUT ISSUING…”
In re K.W., 925 N.E.2d 181 (Ohio Ct. App. 2010). “” MCCS relied on this provision in its motion to bypass reunification efforts, and the trial court agreed that such efforts were not required in this case.”
In re A.A., 2016 Ohio 2992 (Ohio Ct. App. 2016).
In re M.J.C., 2019 Ohio 2353 (Ohio Ct. App. 2019).
In re Y.W., 2017 Ohio 4218 (Ohio Ct. App. 2017).
— Ohio Rev. Code § 2151.419(A)(3) — 3 cases
In re M.J.C., 2019 Ohio 2353 (Ohio Ct. App. 2019).
In Re Nicholas P., 863 N.E.2d 1102 (Ohio Ct. App. 2006).
In re S.C., 2012 Ohio 3432 (Ohio Ct. App. 2012).
— Ohio Rev. Code § 2151.419(A)(B) — 1 case
In re J.H., 2013 Ohio 1423 (Ohio Ct. App. 2013).
— Ohio Rev. Code § 2151.419(B) — 6 cases
In re C.F., 113 Ohio St. 3d 73 (Ohio 2007). “31(A)(3)(b), 1 and that before removing them, it had made reasonable efforts pursuant to R.C. 2151.419 to prevent their removal from the home, to eliminate the need for their continued removal, or to make it possible for them to return home.”
In re C.B.C., 2016 Ohio 916 (Ohio Ct. App. 2016). “” However, the reasonable efforts statute, R.C. 2151.419, does not use the phrase “reunify the family.”
In re N.R., 2021 Ohio 1589 (Ohio Ct. App. 2021).
In re J.W., 2013 Ohio 4368 (Ohio Ct. App. 2013).
In re D.S., 2018 Ohio 3794 (Ohio Ct. App. 2018).
— Ohio Rev. Code § 2151.419(B)(1) — 44 cases
In re J.G., 2013 Ohio 417 (Ohio Ct. App. 2013).
In re S.W., 2023 Ohio 118 (Ohio Ct. App. 2023).
In re R.P., 2013 Ohio 5728 (Ohio Ct. App. 2013).
In re L.G., 2022 Ohio 529 (Ohio Ct. App. 2022). “In each of its journal entries, the magistrate included the following reasonable- efforts findings: FINDING WHETHER REASONABLE EFFORTS WERE MADE BY AGENCY (ORC §2151.419) The Court further finds that reasonable efforts were made to prevent the removal of the child from the home,…”
In re C.B.C., 2016 Ohio 916 (Ohio Ct. App. 2016). “” However, the reasonable efforts statute, R.C. 2151.419, does not use the phrase “reunify the family.”
— Ohio Rev. Code § 2151.419(D)(2)(e) — 1 case
In re J.D., 2015 Ohio 4114 (Ohio Ct. App. 2015).
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