Ohio Rev. Code Ann. § 2151.414

For the abandonment factor in § 2151.414(E)(10), abandonment turns on more than ninety days without visitation or contact and does not require proof that the parent intended to relinquish custody.

In re I.H. · filed 2017-03-07(E)(10)

This court has rejected appellant's same argument in another case. In In re D.P., 10th Dist. No. 06AP-780, 2007-Ohio-1703, this court held that "R.C. 2151.011(C) does not contain a requirement of any particular 'intent' on behalf of the parent; rather, the provision defines 'abandonment' solely in terms of the time between contacts." ... Therefore, father's argument regarding his lack of intent to abandon the children is irrelevant.

A parent's limited attempt to reconnect after the agency moves for permanent custody does not erase prolonged abandonment, the absence of a parent-child bond, or those facts' weight in the best-interest analysis.

In re T.T. · filed 2017-03-15(D)(1)(a), (e); (E)(10)

Father visited T.T. once at the beginning of the case and had no further contact with him for the next one and one-half years. It was not until after CSB moved for permanent custody that Father again had any contact with CSB or T.T. Father visited T.T. during March 2016 and, although CSB wanted to extend his time with the child, Father declined CSB’s offer for an overnight visit. He saw the child for one two-hour visit and then returned to California. By the end of this case, T.T. was five years old, had seen Father only a few times during his life, and had no parent-child bond with him.

A parent who fails to visit or contact a child for more than 150 days without persuasive explanation is subject to the statutory abandonment presumption.

In re T.P. · filed 2016-01-11(B)(1)(b)

However, Mother fails to provide a persuasive argument as to why she was unable to visit or maintain contact with L.S. for more than 150 days between the end of April 2014 and October 2014 when she visited L.S. briefly when she was in town for a review hearing.

When a child is abandoned, the agency is not required to make reasonable reunification efforts before permanent custody.

In re D.M. · filed 2016-03-30(B)(1)(b)

Further, because the trial court found that D.M. had been abandoned, it was not required to find that the agency had to make reasonable efforts.

A parent may be found to have abandoned children after more than ninety days without contact even when visitation was suspended, if the parent could have restored visitation by complying with sobriety and treatment conditions but chose not to do so.

In re H.F · filed 2014-11-03(B)(1)(b)

Father could have begun visiting again by complying with the trial court’s order of October 2013, but Father chose not to do so. Father intentionally chose to delay in starting his case plan services. As the statute defines “abandonment” as failure to make contact for more than ninety days, the trial court’s finding that Father abandoned H.F. and A.W. is not against the manifest weight or sufficiency of the evidence.

A finding that a child is abandoned under subsection (B)(1)(b) satisfies the first prong for permanent custody, leaving the court to determine whether permanent custody serves the child's best interest.

In re A.M. · filed 2013-09-23(B)(1)(b)

A trial court's finding of abandonment under R.C. 2151.414(B)(1)(b) will satisfy the first prong of the permanent custody test, allowing the court to move on to the second prong of considering whether the grant of permanent custody to the agency is in the best interest of the child. ... Accordingly, although the trial court in the case sub judice commendably made the additional effort to render a decision under R.C. 2151.414(B)(1)(a) as well, we find no reversible error in the court’s finding of abandonment under R.C. 2151.414(B)(1)(b), and the court’s decision in regard to grounds for permanent custody was not against the manifest weight of the evidence.

Section 2151.414(B)(1)(b) permits permanent custody when clear and convincing evidence establishes that permanent custody is in the child’s best interest and that the child is abandoned.

In re R.B. · filed 2013-12-23(B)(1)(b)

R.C. 2151.414(B) establishes a two-pronged analysis the trial court must apply when ruling on a motion for permanent custody. ... First, the evidence shows Father abandoned R.B. ... For purposes of R.C. 2151.414(B)(1)(b), “abandoned” is defined by R.C. 2151.011(C), which provides that “a child shall be presumed abandoned when the parents of the child ... have failed to visit or maintain contact with the child for more than ninety days, regardless of whether the parents resume contact with the child after that period of ninety days.”

A parent's failure to visit or maintain contact with a child for more than ninety days creates a presumption of abandonment and satisfies the first prong of the permanent-custody test under R.C. 2151.414(B)(1)(b).

In re J.G. · filed 2014-06-19(B)(1)(b)

For the purposes of this statute, “abandoned” is defined by R.C. 2151.011(C), which provides that “a child shall be presumed abandoned when the parents of the child have failed to visit or maintain contact with the child for more than ninety days, regardless of whether the parents resume contact with the child after that period of ninety days.” ... A trial court’s finding of abandonment under R.C. 2151.414(B)(1)(b) will satisfy the first prong of the permanent custody test, thus allowing the court to move on to the second prong of considering whether the grant of permanent custody to the agency is in the best interest of the child.

Clear and convincing evidence of abandonment and that permanent custody is in the child's best interest supports an award of permanent custody under Section 2151.414(B).

In re C.K. · filed 2014-07-14(B)(1)(b)

Upon review, we find the trial court's conclusions on abandonment under R.C. 2151.414(B) and best interest are supported by clear and convincing evidence. The trial court did not err in granting permanent custody of the child to appellee.

A finding of abandonment under Section 2151.414(B)(1)(b) satisfies the first prong of the permanent-custody test, after which the court considers whether permanent custody is in the child's best interest.

In re C.W. · filed 2014-07-24(B)(1)(b)

We note a trial court's finding of abandonment under R.C. 2151.414(B)(1)(b) will satisfy the first prong of the permanent custody test, allowing the court to move on to the second prong of considering whether the grant of permanent custody to the agency is in the best interest of the child.

Section 2151.414(E)(10)'s abandonment factor is not established without evidence satisfying the statutory temporal requirement that the parent failed to visit or maintain any contact for more than ninety days.

In re K.M. · filed 2024-06-04(E)(10)

Here, while K.M.’s foster mother testified appellant did not visit K.M. from August to December 2018, there is no testimony to demonstrate appellant failed to maintain contact of any sort with K.M. Furthermore, no testimony expressly states appellant also failed to visit T.M. during this period or that appellant failed to maintain contact with T.M. As a result, we disagree with the trial court that R.C. 2151.414(E)(10) is met as to either child.

A statutory presumption of abandonment, together with evidence of serious abuse, supported permanent custody.

In re J.L. · filed 2026-02-19(B)(1)(b)

R.C. 2151.011(C) provides that "[f]or purposes of this chapter, a child shall be presumed abandoned when the parents of the child have failed to visit or maintain contact with the child for more than ninety days, regardless of whether the parents resume contact with the child after that period of ninety days." ... This in conjunction with a finding of abandonment more than adequately supports the trial court's decision.

A failure to maintain contact for more than ninety days supports the statutory presumption of abandonment.

In re A.C. · filed 2026-05-26(B)(1)(b)

The evidence clearly and convincingly supported a finding under R.C. 2151.414(B)(1)(b) related to Mother.

Section 2151.414(B)(1)(d) requires a child to have been in agency temporary custody for at least 12 months of a consecutive 22-month period before the permanent-custody motion is filed, with entry into temporary custody measured from the earlier of adjudication or 60 days after removal.

In re M.T. · filed 2013-09-30(B)(1)(d)

In considering how long M.T. had been in the temporary custody of the agency under R.C. 2151.414(B)(1)(d), the statute proscribes that a child enters temporary custody “on the earlier of the date the child is adjudicated * * * or the date that is sixty days after the removal of the child from home.” R.C. 2151.414(B)(1)(d). In this case, we rely on the fact that M.T. was adjudicated dependent on September 23, 2011. Additionally, the child must have been in temporary custody of the agency for at least 12 months of a consecutive 22-month period before the motion for permanent custody is filed in order to satisfy this section. In re C.W., 104 Ohio St.3d 163, 2004-Ohio-6411, ¶ 26. The motion for permanent custody was filed on November 28, 2012. Having been in temporary custody from September 23, 2011 through November 28, 2012, M.T.’s situation meets the requirements of R.C. 2151.414(B)(1)(d).

Section 2151.414(B)(1)(a) permits an agency to seek permanent custody before a child has spent twelve months in agency custody if the child cannot or should not be placed with the parents within a reasonable time under the subsection (E) factors and permanent custody is in the child's best interest.

In re C.K. · filed 2016-12-02(B)(1)(a)

LCCS filed its motion for permanent custody of C.S. and C.K. on August 13, 2014, pursuant to R.C. 2151.414(B)(1)(a), which permits such a motion to be filed where the child has not been in the custody of a children services agency for more than 12 months if the trial court determines that the child cannot or should not be placed with the parents within a reasonable period of time based on the factors set forth in R.C. 2151.414(E)(1-16). The trial court must also find that it is in the best interest of the child for permanent custody to be granted to the children services agency. ... Based on the foregoing, we find that the trial court did not err by granting permanent custody to LCCS when the children had not been in the agency’s custody for 12 months at the time the permanent custody motion was filed.

Uninterrupted agency placement for twelve or more months of a consecutive twenty-two-month period satisfies subsection (B)(1)(d).

In re N.A. · filed 2025-04-17(B)(1)(d)

Here, Mother does not contest the juvenile court’s finding pursuant to R.C. 2151.414(B)(1)(d), that the child had been in agency custody for “twelve or more months of a consecutive twenty-two-month period.” We nevertheless find that the record supports this finding based on the child’s uninterrupted placement with the agency since December 11, 2021.

The twelve-of-twenty-two-month ground is satisfied when the child was in agency temporary custody for twelve of the twenty-two months preceding the filing of the permanent-custody motion.

In re R.W. · filed 2025-10-16(B)(1)(d)

Neither party disputes R.W. had been in the temporary custody of the Agency for twelve of the last twenty-two months when the motion for permanent custody was filed, which satisfies the statutory requirement pursuant to R.C. 2151.414(B)(1)(d).

When the twelve-of-twenty-two-month ground applies, the agency need not also prove that the child cannot or should not be placed with a parent within a reasonable time.

In re H.C. · filed 2026-01-05(B)(1)(d)

Thus, R.C. 2151.414(B)(1)(a), by its terms, was inapplicable. ... “under the plain language of R.C. 2151.414(B)(1)(d), when a child has been in a ... children services agency’s temporary custody for twelve or more months of a consecutive twenty-two-month period, a trial court need not find that the child cannot or should not be placed with either parent within a reasonable time”

Section 2151.414(B)(1)(d) permits permanent custody when a child has spent at least 12 months of a consecutive 22-month period in an agency's temporary custody and permanent custody is in the child's best interest.

In Re Bicanovsky, Unpublished Decision (6-10-2004) · filed 2004-06-10(B)(1)(d)

Additionally, at the time of the final hearing, all of the children had been in appellee's temporary custody for more than 12 months of a consecutive 22-month period. ... Therefore, the trial court met the first part of the two part-test for granting permanent custody to appellee.

When a child has been in agency temporary custody for 12 of 22 consecutive months, § 2151.414(B)(1)(d) does not require a separate finding about placement with a parent or the agency’s reunification efforts.

In the Matter of Katrina T., Unpublished Decision (6-18-2004) · filed 2004-06-18(B)(1)(d)

Undisputed clear and convincing evidence established that Katrina and Kaylee were in the temporary custody of the appellee for 12 or more months of a consecutive 22 month period ending on or after March 18, 1999. Thus, even though the juvenile court addressed the fact that appellant's children could not be placed with appellant within a reasonable time or should not be placed with her, and, in doing so, discussed the question of reasonable case planning and efforts by the agency to remedy the conditions that caused the removal of the children from the appellant's home, it was unnecessary to the resolution of this case.

When a child has been in temporary agency custody for twelve months of a consecutive twenty-two-month period, § 2151.414(B)(1)(d) does not require a separate finding that the child cannot or should not be placed with a parent within a reasonable time.

In Re Thompson, Unpublished Decision (7-7-2004) · filed 2004-07-07(B)(1)(d)

Accordingly, the court's finding with respect to R.C. 2151.414 (B)(1)(a) is irrelevant, as the juvenile court had already determined that the twins had been in the custody of PDJFS for longer that twelve months of a twenty-two month consecutive period, under R.C. 2151.414 (B)(1)(d).

When a child has spent at least twelve months of a consecutive twenty-two-month period in temporary agency custody, § 2151.414(B)(1) requires the court to determine whether permanent custody is in the child's best interest.

In Re Kaylee P., Unpublished Decision (7-16-2004) · filed 2004-07-16(B)(1)(d)

In the case before us, R.C. 2151.414 (B)(1)(d) is clearly relevant, as it states that "* * * the child has been in the temporary custody of one or more public children services agencies or private child placing agencies for twelve or more months of a consecutive twenty-two month period ending on or after March 18, 1999." ... Pursuant to R.C. 2151.414 (B)(1), then, the only other consideration to be made by the trial court was whether granting permanent custody to appellee was in Kaylee's best interest.

Section 2151.414(B)(1)(d) permits permanent custody when clear and convincing evidence shows that the child spent at least 12 months of a consecutive 22 month period in agency custody and permanent custody is in the child's best interest.

In Re B.R., Unpublished Decision (7-22-2004) · filed 2004-07-22(B)(1)(d)

Here, unlike in Campbell, the juvenile court granted CCDCFS' motion and awarded permanent custody of the children to CCDCFS because of the clear and convincing evidence that the children had been in CCDCFS' custody for 12 or more months in a consecutive 22 month period and that permanent custody would be in the best interests of the children.

Section 2151.414(B)(1)(d) permits permanent custody when clear and convincing evidence establishes that a child spent at least 12 of 22 consecutive months in an agency’s temporary custody and permanent custody is in the child’s best interest.

In Re Johnson, Unpublished Decision (7-22-2004) · filed 2004-07-22(B)(1)(d)

Upon our review of the record, we conclude that the trial court correctly determined that the children had been in temporary custody of a public children services agency for 12 or more months of a consecutive 22-month period. R.C. 2151.414 (B)(1)(d) was established by clear and convincing evidence.

When a child has been in temporary custody for at least 12 months of a consecutive 22-month period, the court need not analyze under subsection (E)(1) whether the parents remedied the conditions that caused removal; it must find by clear and convincing evidence that permanent custody is in the child's best interest.

In Re L.D., Unpublished Decision (8-2-2004) · filed 2004-08-02(E)(1)

The finding that the child has been in temporary custody for at least 12 months of a consecutive 22-month period precludes a determination required by R.C. 2151.414 (E) of whether the parent has remedied the conditions which caused the removal of the children. ... Accordingly, the trial court was not required to conduct an analysis under R.C. 2151.414 (E)(1).

When a child has been in agency custody for at least twelve of twenty-two consecutive months, the court need not find that the child cannot or should not be placed with a parent within a reasonable time; it must consider the child's best interests.

In Re Berkley, Unpublished Decision (9-3-2004) · filed 2004-09-03(B)(1)(d)

Pursuant to the plain language of R.C. 2151.414 (B)(1)(d), when a child has been in a children services agency's temporary custody for twelve or more months of a consecutive twenty-two month period ending on or after March 18, 1999, a trial court need not find that the child cannot or should not be placed with either parent within a reasonable time.

When a child has spent at least 12 of 22 consecutive months in agency custody, the court may decide permanent custody based on the child's best interest without determining whether the child can be placed with a parent within a reasonable time.

In the Matter of Abram, Unpublished Decision (9-21-2004) · filed 2004-09-21(B)(1)(d)

Consequently, because R.C. 2151.414 (B)(1)(d) was established, the next issue is whether the trial court's finding that clear and convincing evidence established that the awarding of permanent custody of the children to FCCS was in the children's best interest was supported by competent, credible evidence.

When a child has been in agency custody for twelve months of a consecutive twenty-two-month period, the court need not determine under subsection (E) whether the parent remedied the conditions that led to removal.

In Re C.C., Unpublished Decision (9-30-2004) · filed 2004-09-30(B)(1)(d)

Here, the evidence at trial demonstrated that the children have been in the temporary custody of CCDCFS for 28 months at the time of trial, which supports the court's finding, pursuant to R.C. 2151.414 (B)(1)(d), that the children have been in the temporary custody of CCDCFS for "twelve or more months of a consecutive twenty-two month period." ... Thus, despite appellant's argument to the contrary, the trial court did not err when it bypassed a determination under R.C. 2151.414 (E) as to whether appellant remedied the conditions which caused her five children to be removed.

Section 2151.414(B)(1)(d) allows permanent custody based on twelve months of agency temporary custody within a consecutive twenty-two-month period, together with a finding that permanent custody is in the child's best interest.

In Re J.T., Unpublished Decision (10-15-2004) · filed 2004-10-15(B)(1)(d)

We conclude that the findings the trial court made necessarily imply that the children were in the custody of the GCCSB agency at least twelve months out of a consecutive twenty-two month period ending on or after March 18, 1999, which finding, together with the trial court's finding that it is in the best interests of the children that their custody be awarded to the GCCSB, for which finding there is support in this record, provides an independent basis for the award of permanent custody to the GCCSB, pursuant to R.C. 2151.414 (B)(1)(d).

Section 2151.414(B)(1)(d) permits the custody requirement for permanent custody to be met when a child has spent 12 of the preceding 22 months in an agency's temporary custody.

In Re Guy, Unpublished Decision (10-25-2004) · filed 2004-10-25(B)(1)(d)

In her Assignments of Error, Appellant does not challenge the trial court's finding that the minor children were in the temporary custody of the agency for 12 of the past 22 months. Such a finding is enough to satisfy the requirements of R.C. 2151.414 (B)(1).

When a child has been in agency temporary custody for at least twelve months of a consecutive twenty-two-month period, § 2151.414(B)(1)(d) permits permanent custody without a finding that the child cannot be placed with a parent within a reasonable time.

In Re T.P. C.P., Unpublished Decision (10-29-2004) · filed 2004-10-29(B)(1)(d)

As for Pritchett's argument that the children could be reunited with her within a reasonable time, we note that they have been in the temporary custody of MCCS for twelve or more months of a consecutive twenty-two month period. Under such circumstances, a trial court may award permanent custody without the need to determine whether a child can be placed with a parent within a reasonable time.

When a child has been in agency temporary custody for at least twelve of twenty-two consecutive months, the court need not find that the child cannot or should not be placed with either parent before deciding the child's best interest.

In Re J.L., Unpublished Decision (11-10-2004) · filed 2004-11-10(B)(1)(d)

Therefore, the trial court is not required to make a finding that the children cannot or should not be placed with either parent before moving on to the best interest determination, pursuant to R.C. 2151.414 (B)(1)(d).

A finding that a child spent at least 12 months of a consecutive 22-month period in agency custody, together with a best-interest finding, is sufficient to support permanent custody.

In re V.J. · filed 2016-09-19(B)(1)(d)

This finding alone, in conjunction with a best-interest finding, is sufficient to support the grant of permanent custody.

When a child has been in an agency’s temporary custody for at least 12 months of a consecutive 22-month period, the court need not find that the child cannot or should not be placed with either parent.

In re D.C.-F. · filed 2024-04-01(B)(1)(d)

Under the plain language of R.C. 2151.414(B)(1)(d), when a child has been in an agency’s temporary custody for 12 or more months of a consecutive 22-month period, a trial court need not find that the child cannot be placed with either parent within a reasonable time or should not be placed with the parents.

Section 2151.414(B)(1)(d) allows a court to grant permanent custody when a child has spent at least 12 months of a consecutive 22-month period in agency temporary custody and permanent custody is in the child’s best interest.

In re L.A. · filed 2024-09-06(B)(1)(d)

In the case at bar, the record establishes by competent credible evidence that L.A. 1 had been in the temporary custody of the SCJFS for over twelve months of a consecutive 22-month period at the time the motion for permanent custody was filed.

Section 2151.414(B)(1)(a) permits permanent custody even when a child has spent fewer than twelve months in agency custody during a consecutive twenty-two-month period, if its other requirements are met.

In re P.S. · filed 2025-10-14(B)(1)(a)

This statutory subsection specifically permits granting permanent custody to JFS when a child has not been with an agency for twelve or more months of a consecutive twenty-two month period, defeating Father’s argument.

Section 2151.414(B)(1)(d) supplies a ground for permanent custody when a child has spent at least twelve months of a consecutive twenty-two-month period in agency temporary custody.

In Re S. A., 90116 (2-21-2008) · filed 2008-02-21(B)(1)(d)

Thus, the evidence at trial conclusively supports the court's finding, pursuant to R.C. 2151.414 (B)(1)(d), that S.A. has been in the temporary custody of CCDCFS for "twelve or more months of a consecutive twenty-two month period."

Section 2151.414(B)(1)(d) allows a child’s temporary custody with an agency for at least 12 of 22 months to satisfy the first prong of the permanent custody test.

In re G.B. · filed 2020-06-08(B)(1)(d)

Specifically, neither parent disputes that the child had been in the agency’s temporary custody for at least 12 of 22 months at the time LCCS filed its motion for permanent custody. The agency expressly asserted that alternative first-prong ground in its motion, and the juvenile court found same. The juvenile court’s alternative finding pursuant to R.C. 2151.414(B)(1)(d) is fully supported by the record. Accordingly, this Court need not determine whether the first prong of the permanent custody test was also satisfied pursuant to R.C. 2151.414(B)(1)(a) grounds.

Section 2151.414(F) recognizes a parent’s right to appeal an adverse permanent-custody ruling but gives the child no independent right to appeal when neither the agency nor parent appeals.

In re T.S. · filed 2019-03-14(F)

R.C. 2151.414(F) specifically acknowledges a parent's right to appeal a PCC determination after an adverse ruling, but makes no mention of a child's right to appeal. Thus, with neither FCCS nor mother appealing, appellant had no independent legal right, separate and apart from FCCS and mother, to pursue an appeal.

Section 2151.414(F) ends a parent’s party status only prospectively after permanent custody, excluding the parent from future proceedings concerning the child but not barring a challenge to the permanent-custody judgment.

In re J.W. · filed 2013-10-02(F)

Although R.C. 2151.414(F) provides that parents “cease to be parties” after the permanent custody decision, “[l]ogically, this provision can only be meant to operate prospectively, excluding the parents from future proceedings relating to the child, such as review hearings.” In re Phillips, 12th Dist. Butler No. CA 2003-03-062, 2003-Ohio-5107, ¶ 8. Moreover, because R.C. 2151.414(F) further provides that it is “not intended to eliminate or restrict any right of the parents to appeal the granting of permanent custody of their child to a movant pursuant to this section[,]” the parents similarly retain their rights to “challeng[e] the validity of the judgment rendered in the proceeding to which [she] was a party.” Id.

Once a permanent-custody order issues, the child’s parents cease to be parties and lack standing to move to vacate that judgment.

In re M.H. · filed 2018-09-19(F)

R.C. 2151.414(F) provides that “[t]he parents of a child for whom the court has issued an order granting permanent custody pursuant to this section, upon the issuance of the order, cease to be parties to the action.” A non-party lacks standing to file a Civ.R. 60(B) motion to vacate judgment.

The permanent-custody best-interest determination focuses on the child rather than the parent.

In re C.J. · filed 2014-06-05(C)

The “best interest determination” focuses on the child, not the parent. R.C. 2151.414(C); In re Awkal, 95 Ohio App.3d 309, 315, 642 N.E.2d 424 (8th Dist.1994).

A best-interest finding under R.C. 2151.414(D) may be supported by a parent's failure to complete significant case-plan services, lack of parenting improvement, the guardian ad litem's permanent-custody recommendation, lengthy foster care, and mixed evidence of family bonds and the children's wishes.

In re A.J. · filed 2014-06-24(D)

Despite mother's arguments, the record reflects competent, credible evidence for the trial court to find that an award of permanent custody is in the best interest of the children. Specifically, mother has failed to complete significant portions of her case plan, including attending personal, as well as her children's, counseling sessions and failing to take drug screens. Monica Tinsley, mother's case worker, testified that mother has made little improvement in her parenting or anger management over the course of this case and displays little inclination to do so. This testimony is competent and credible evidence to support the trial court's conclusion that mother “is without ability, commitment, discipline or compassion” to provide a secure placement for her children. ... Further, the children had been in foster care and not in their mother's care for a lengthy period of time. The evidence of bonding between mother and children and among the children themselves was mixed at best, as was evidence of the wishes of the children. Lastly, mother's concern about the children's potential future placements in foster homes is pure speculation.

A child's signs of stress when removed from a parent or foster family are relevant to the permanent-custody best-interest determination even without medical testimony diagnosing separation anxiety.

In re A.W. · filed 2014-07-21(D)(1)

The fact that the child showed signs of stress when removed from both her mother and foster family, regardless of whether those signs could be medically diagnosed as separation anxiety, is certainly a relevant consideration the court may take into account when determining whether permanent custody is appropriate. To hold otherwise would place an unnecessary evidentiary burden on children service agencies when dealing with the already difficult nature of permanent custody proceedings.

In determining best interest, the court must evaluate a parent's recent progress in light of the parent's history and the full record rather than treating that progress in isolation.

In re N.B. · filed 2015-01-29(D)

We acknowledge that at the time of the dispositional hearing Mother had made some progress. But in considering the children’s best interest, Mother’s then-recent progress had to be viewed in light of her background and the facts.

A stable foster placement that actively addresses a child's behavioral needs may support permanent custody when the parent has repeatedly missed hearings and visits and failed to pursue substance-abuse treatment despite ample opportunity.

In re K.W. · filed 2015-10-19(D)(1)

Throughout these proceedings, appellant has missed court hearings, skipped visitation sessions, and has not taken appropriate measures in her substance abuse treatment. Although appellant requests additional time to complete the steps necessary for reunification, appellant has already been provided with ample opportunity to take these corrective steps and has been unwilling to take those measures prior to the agency's filing for permanent custody. While in foster care, K.W. has been provided with a stable and comfortable environment and her foster family has been active in seeking the necessary support and treatment for K.W.'s behavioral issues.

The permanent-custody best-interest determination focuses on the child rather than the parent.

In re Z.D. · filed 2015-12-17(D)

The “best interest determination” focuses on the child, not the parent.

When subsection (D)'s factors guide a legal-custody decision, the parties must present enough evidence for the court to consider all best-interest factors; brief conclusory bond testimony may be insufficient.

In re T.R. · filed 2018-03-28(D)

The trial court was required to consider all of the best interest factors, but its consideration of those factors was necessarily limited to the evidence presented by the parties. Because the parties presented so little evidence on the best interest factors, it would have been impossible for the trial court to adequately consider the child’s best interest.

The statutory best-interest determination focuses on the child rather than the parent.

In re J.C. · filed 2021-06-02(D)

The best interest determination, however, focuses on the child, not the parent.

Section 2151.414(D)(1)'s best-interest factors supported permanent custody where the child was bonded to the foster parents, the parents had not consistently visited, and the child wished to remain with the foster family.

In re N.S. · filed 2023-02-24(D)(1)

The evidence relating to the best interest factors in R.C. 2151.414(D)(1) supported the trial court’s best interest finding. The record before us contains competent, credible evidence by which the trial court could have formed a firm belief or conviction that the grant of permanent custody to MCCS was in N.S.’s best interest.

Section 2151.414(D)(1)'s best-interest factors supported permanent custody where the child needed secure placement, was strongly bonded to caregivers meeting his special needs, and had parents with inconsistent or limited relationships with him.

In re N.F. · filed 2023-02-27(D)(1)

In sum, the trial court took all of the evidence into account, analyzed the appropriate statutory factors, and filed a thorough judgment entry determining that it was in N.F.’s best interests to grant MCCS’s permanent custody motion. After reviewing the record, we do not find that the trial court erred in this matter.

Section 2151.414(D)(1)'s best-interest standard was satisfied where the record showed that permanent placement would foster the children's growth, stability, and security and that their mother could not provide those things at trial.

In re G.A. · filed 2023-03-03(D)(1)

Based on our review of the record, we conclude that the juvenile court did not err in determining that an award of permanent custody to CCDJFS was in the children's best interest. There is more than sufficient credible evidence to support the juvenile court's determination that the statutory standards for permanent custody have been met. As noted above, the children's best interests are served by being placed in a permanent situation that fosters growth, stability, and security. The record establishes that Mother could not provide these things at the time of trial.

Section 2151.414(D)(1)'s best-interest standard supported permanent custody where the parent did not address mental-health, substance-abuse, and unsafe-home concerns, while the child was safe and secure with caregivers, wanted to remain there, and the guardian ad litem favored permanent custody.

In re L.S. · filed 2023-03-08(D)(1)

Based on a thorough review of the record, this is not the exceptional case in which the trier of fact clearly lost its way and created a manifest miscarriage of justice by finding that permanent custody was in the best interest of the child. CSB removed L.S. from an unsafe, unsanitary, and unstable home. Mother failed to comply with her mental health, substance abuse, and basic needs case plan objectives. The child is in a safe and secure home environment with kinship caregivers who meet his needs and recognize his desire to maintain a relationship with Mother. The caregivers are also in a position to honor the child’s memories of Father. L.S. does not want to return to Mother’s custody, and the guardian ad litem opined that permanent custody would be in the child’s best interest.

Clear and convincing evidence did not establish that permanent custody was in the child's best interest where the child was bonded to and wanted to live with his father, the father consistently showed commitment and initiative, and the agency had no definite alternative placement plan.

In re F.D. · filed 2023-03-08(D)(1)

Given that CSB had no definitive plans for the child’s placement, that the child disrupted from every prior placement including therapeutic foster homes, that F.D. has a bond with Father and wants to live with him, and that Father has remained consistent in his commitment to the child, this Court concludes that the juvenile court’s finding that permanent custody was in the best interest of the child is against the manifest weight of the evidence. ... However, this Court sustains Father’s second assignment error, as CSB did not present clear and convincing evidence that permanent custody is in the best interest of F.D. under the circumstances at this time.

Section 2151.414(D)(1)'s best-interest standard supported permanent custody where the children were bonded to foster parents who wished to adopt, needed permanence, and the parents had been inconsistent in services.

In re J.M. · filed 2023-04-27(D)(1)

Based upon the testimony presented, we do not find the trial court lost its way in making the decisions to terminate mother's parental rights and grant permanent custody of the children to SCDJF. We do not find any manifest miscarriage of justice.

Section 2151.414(D)(1)'s best-interest standard supported permanent custody where the parent had not remedied safety and substance-abuse concerns and the child was healthy, bonded to foster parents, and in an adoptive home.

In re G.M. · filed 2023-09-27(D)(1)

Ms. Davenport also testified that G.M. is healthy with no medical, developmental or behavioral concerns with the foster family. G.M. has bonded well with the foster parents, calling them mom and dad. He calls their new baby his brother. The foster family’s home is appropriate, they are able to care for G.M.’s needs, and they are interested in adopting G.M. ... Based on the foregoing, we find the Agency presented sufficient evidence to demonstrate by clear and convincing evidence that G.M. cannot and should not be placed with Appellant, and that it is in G.M.’s best interest to grant the Agency permanent custody.

Section 2151.414(D)(1)'s best-interest factors supported permanent custody where the children had no parent-child relationship with their incarcerated father, needed stability after living in temporary placements their entire lives, and lacked any suitable relative placement.

In re Q.S. · filed 2023-10-04(D)(1)

She opined that permanent custody was in the best interest of these children so they could achieve stability in their lives. The children, who were two and almost three years old at the time of the hearing, had lived in temporary placements for their entire lives. They needed a legally secure permanent placement, and CSB had been unable to find any suitable relatives to provide them with a stable home. Father had no relationship with the children and, at the time of the hearing, was facing another year and a half of incarceration. The trial court therefore concluded that a legally secure permanent placement would be achieved only by placing the children in the permanent custody of CSB.

The statutory best-interest finding may rest on evidence that an abandoned child has no parental bond, is thriving in a foster-to-adopt home, and has no other appropriate relative placement.

In re J.E. · filed 2023-10-23(D)(1)

These findings, coupled with the evidence in the record that showed J.E. had been receiving weekly counseling sessions while in the temporary custody of FCCS, had been taking the necessary medication to address his ADHD, and appeared happy and doing well in his current foster-to-adopt home, convinces this court that the juvenile court did not err in its decision finding a grant of permanent custody to FCCS was in J.E.'s best interest.

A parent's history of drug abuse remains directly relevant to the Section 2151.414(D)(1) best-interest analysis when it bears on the parent's relationship with the children and their custodial history.

In re L.T. · filed 2023-11-15(D)(1)

Mother’s parenting history was directly relevant to the trial court’s best interest determination, as it pertained to Mother’s relationship with the children and their custodial history. See R.C. 2151.414(D)(1); R.C. 3109.04(F)(1).

Section 2151.414(D)(1)'s best-interest factors favored permanent custody where the parent did not obtain recommended counseling or parenting education, could not verify improved home conditions, lived with a registered sex offender, and the child was bonded to an appropriate foster family.

In re R.R. · filed 2023-12-21(D)(1)

Appellant did complete the psychological evaluation and has taken her prescribed medications. However, she has not sought any counseling services recommended by psychological evaluation, she canceled her parent educator classes, and has not verified the poor conditions of her home have improved. In addition, R.R. has bonded with the foster family who has an appropriate home for R.R. Appellant is still residing with her father who is a registered sex offender. Accordingly, the trial court did not abuse its discretion in failing to find Appellant made significant progress in ameliorating the issues which caused the child to be removed.

Under section 2151.414(D)(1), recent remediation and sobriety do not outweigh the controlling best-interest inquiry when returning children would jeopardize their growth, stability, and security.

In re N.G. · filed 2024-01-08(D)(1)

But, although we commend Mother for her newfound sober lifestyle, the fact that Mother may have substantially remedied many of those initial concerns that caused the children's removal is not the only issue at play. It is not even the most salient. The main concern – one that overrides all else – is what is in the best interest of the children. ... The record in this case indicates that returning the children to Mother's care, even if just for a brief, temporary reunification, could have significant impact on their development and potential to grow and mature into well-rounded adults given the overwhelming harm that she caused to the children while they were in her care.

Section 2151.414(D)(1)'s best-interest inquiry permits reliance on properly credited drug-test evidence when evaluating whether permanent custody serves the children.

In re A.V. · filed 2024-03-25(D)(1)

The juvenile court, as the trier of fact, clearly found Lemberg's testimony about the accuracy of her laboratory's test results credible. This was not error. It is the juvenile court, not this court, that is in the best position to determine the credibility of witnesses and determine the weight to be given to the evidence.

Section 2151.414(D)(1)'s best-interest factors supported permanent custody where the parents had minimal involvement, the child had spent most of his life with a suitable caregiver, and the guardian ad litem recommended agency custody.

In re A.M. · filed 2024-03-28(D)(1)

The juvenile court considered the relevant statutory factors in granting permanent custody and its ... findings were supported by competent, credible evidence. Given the length of time A.B. cared for A.M. and how he came to be in her care, we cannot say the grant of permanent custody was against the manifest weight of the evidence or that the judgment created a manifest injustice.

Section 2151.414(D)(1)'s best-interest standard favored permanent custody for a neurodivergent child who regressed in the mother's care but made gains with consistent therapeutic support in foster care.

In re C.K. · filed 2024-04-15(D)(1)

C.K. is neurodivergent with multiple diagnoses that require consistent support for him to thrive and become self-sufficient. The evidence showed that while C.K. was in foster care, he received consistent therapeutic support so that he mastered some ability to self-care, his obsessive-compulsive behaviors were reduced, and his speech improved. When C.K. was returned to Mother’s care, C.K. notably regressed. ... In this case, C.K. requires an environment that will foster consistency, stability, and security to promote his growth and self-sufficiency. We find no error for the trial court to find it was in the best interests of C.K. to be placed in the permanent custody of KCDJFS.

Section 2151.414(D)(1)'s best-interest factors supported permanent custody where three medically complex children were bonded to caregivers who met their needs, the parents visited inconsistently, and the parents lacked stable employment and a concrete care plan.

In re N. Children · filed 2024-04-19(D)(1)

The record demonstrates that the juvenile court properly considered the relevant best interest factors and weighed the factors to conclude that it is in the best interest of A.N., D.N., and Z.N. to be placed in the permanent custody of HCJFS. Accordingly, we hold the court’s best interest finding was supported by sufficient evidence and was not against the manifest weight of the evidence.

Section 2151.414(D)(1)'s best-interest inquiry may consider a parent's failure to recognize or meet a child's special emotional and medical needs, not merely the parent's substance use.

In re L.S.F. · filed 2024-08-09(D)(1)

Consequently, the court was not just focused on Mother’s drug use. Instead, the court considered many other points in deciding the ... child’s best interest.

Clear and convincing evidence did not support permanent custody where the parent completed the housing and mental-health-assessment requirements, the agency could monitor remaining educational concerns through protective supervision, and sibling relationships favored reunification.

In re M.W. · filed 2024-11-07(D)(1)

Mother complied with the requirements of her case plan, obtained stable housing, and ... completed a mental health assessment. While the agency had concerns about Mother’s follow through on educational goals, the primary factor leading to the removal, Mother’s concerns about COVID-19 and her children’s safety have been mostly ameliorated. Additionally, the agency is capable of monitoring Mother’s conduct through an order of protective supervision. ... Based on the foregoing, the juvenile court’s finding that permanent custody was in the best interest of M.W. was not clearly and convincingly supported by the greater weight of the evidence.

Section 2151.414(D)'s best-interest factors supported permanent custody where the parents had not completed services, lacked stable housing, and the children were thriving and bonded in foster care.

In re M.A. · filed 2024-11-13(D)

The mother did not obtain and maintain safe and stable housing until right before the permanent custody hearing. This home had mold growing on one of the ceilings, and the floors were unstable. ... The appellant never requested to be on the case plan and did not see the minor children throughout the pendency of the case. ... Ms. Gadd testified that the minor children are thriving in foster care.

Permanent custody was in the children's best interest where neither parent could provide a permanent stable home and the children had progressed in stable, structured placements.

In re L.F. · filed 2025-05-07(D)(1)

These children had been removed from Mother’s custody in two separate cases, had been in temporary placements for a total of more than two years, and needed a permanent stable home. CSB had been unable to find any suitable relatives who were willing and able to provide a permanent home for any of these children and neither parent was able to do so. In stable and structured homes, the children had made great progress in improving their emotional, behavioral, and developmental wellbeing. They needed permanency to allow their progress to continue.

Section 2151.414(D)’s best-interest factors apply when a court considers placing a child in a permanent planned living arrangement under § 2151.353(A)(5).

In Re M.B., Unpublished Decision (5-26-2004) · filed 2004-05-26(D)

Furthermore, this Court holds that CSB has presented sufficient evidence to prove by clear and convincing evidence that placing M.B. in a PPLA is in her best interest.

Section 2151.414(D) directs the court to consider the listed criteria when deciding whether permanent custody is in a child's best interest.

In Re T.S., Unpublished Decision (7-1-2004) · filed 2004-07-01(D)

The judge's determination under the criteria set forth in R.C. 2151.414 (D) supports the conclusion that permanent custody is in the best interest of the children. Custody has been continuous since the children's placement in June of 2000, and by the continuous custody of the youngest since June of 2001. The record contains clear and convincing evidence that the award of permanent custody was in the best interest of the children.

Section 2151.414(D) requires clear and convincing evidence that permanent custody serves the child's best interest and requires the court to consider the listed best-interest factors.

In the Matter of A.P., Unpublished Decision (8-5-2004) · filed 2004-08-05(D)

In considering an award of permanent custody, the court must first determine whether, by clear and convincing evidence, it is in the best interest of the child to grant permanent custody. R.C. 2151.414 (D). In determining the best interest of the child during the permanent custody hearing, the court must consider the factors listed in R.C. 2151.414 (D), which include the reasonable probability the child will be adopted, the interaction of the child with the child's parents, siblings, and foster parents, the wishes of the child, the custodial history of the child, and the child's need for a legal secure permanent placement.

Section 2151.414(B)(1) requires clear and convincing evidence that granting permanent custody serves the child's best interest.

In Re Lyons Children, Unpublished Decision (9-7-2004) · filed 2004-09-07(B)(1)

Based upon the foregoing, we find the Department presented clear and convincing evidence it was in the best interest of the children to be placed in the permanent custody of the Department.

Section 2151.414(D) requires a best interest finding before a juvenile court awards permanent custody to an agency.

In Re T.G., Unpublished Decision (9-29-2004) · filed 2004-09-29(D)

Before a juvenile court can terminate parental rights and award to a proper moving agency permanent custody of a child, it must find clear and convincing evidence of both prongs of the permanent custody test: ... (2) the grant of permanent custody to the agency is in the best interest of the child, based on an analysis under R.C. 2151.414 (D). ... Given the evidence presented during the original permanent custody hearing, the trial court could reasonably conclude that permanent custody was in the best interests of T.G., K.G., and S.G.

Section 2151.414(D) requires a juvenile court to consider all relevant factors when deciding whether permanent custody is in a child’s best interest.

In re T.S. · filed 2016-08-03(D)

Further, pursuant to R.C. 2151.414(D), a juvenile court must consider the best interest of the child by examining factors relevant to the case including, but not limited to, those set forth in paragraphs 1-5 of subsection (D). ... Our review of the record shows that the trial court considered all of the relevant factors under R.C. 2151.414, as summarized above.

Section 2151.414(D)(1)'s best-interest inquiry permits permanent custody when the benefits of a secure placement outweigh harm from severing the parental bond, supported by clear and convincing evidence.

In re B.S. · filed 2018-02-14(D)(1)

We agree that the evidence demonstrates that any harm of severing the parental bond is outweighed by the benefits of permanency. ... Upon this record, we find the trial court's decision that it was in the best interests of B.S. to be placed in the permanent custody of the Agency is supported by clear and convincing evidence and is not against the manifest weight of the evidence.

Section 2151.414(D)(1) does not require a court to favor a relative if the statutory best interest factors support permanent custody with the agency.

In re M.H. · filed 2022-05-19(D)(1)

The juvenile court was not required to favor the maternal aunt if, after considering the statutory best interest factors, it found permanent custody to the agency was in the child’s best interest.

Section 2151.414(D)(1) requires courts to consider all relevant factors when deciding whether permanent custody is in a child’s best interest.

In re A.D. · filed 2022-07-06(D)(1)

After our review of the record, we find that there was sufficient evidence before the trial court to find, by clear and convincing evidence, that a grant of permanent custody to HCJFS was in A.D.’s best interest.

Section 2151.414(D)(1) requires the court to consider the child's best interest factors when deciding whether to award permanent custody.

In re N.L. · filed 2025-07-28(D)(1)

In light of the foregoing, we conclude that the juvenile court did not err in finding the best interest factors weighed in favor of awarding permanent custody to the Agency. There was sufficient credible evidence to support the juvenile court's determination that awarding permanent custody of the Agency was in the children's best interest, and the juvenile court's determination was not against the manifest weight of the evidence.

Section 2151.414(D) requires courts deciding permanent custody to consider all relevant factors bearing on the child’s best interest.

In re R.Y. · filed 2013-09-13(D)

Having reviewed all of the evidence presented, we cannot conclude that the trial court abused its discretion in concluding that the best interests of the children would be served by awarding permanent custody to MCCS.

Section 2151.414(D)(1) requires courts deciding permanent custody to consider all relevant factors bearing on the child’s best interest, including the child’s relationships, wishes, custodial history, and need for permanence.

In re J.G. · filed 2014-06-16(D)(1)

When determining whether a grant of permanent custody is in a child’s best interest, the juvenile court must consider all the relevant factors, including those enumerated in R.C. 2151.414(D): the interaction and interrelationships of the child, the wishes of the child, the ... custodial history of the child, and the child’s need for permanence in his life.

Section 2151.414(D) requires the juvenile court to consider all relevant factors when deciding whether permanent custody is in a child’s best interest.

In re T.T. · filed 2018-07-25(D)

When determining the child’s best interest under R.C. 2151.414(D), the juvenile court must consider all relevant factors, including the interaction and interrelationships of the child, the child’s wishes, the custodial history of the child, the need for permanence in the child’s ... life, and whether any of the factors set forth in R.C. 2151.414(E)(7) to (11) apply to the facts of the case. ... The trial court reasonably concluded that permanent custody was in the best interest of T.T.

A child’s probability of being adopted is not one of Section 2151.414(D)’s statutory best-interest factors.

In re T.A. · filed 2013-12-23(D)

Moreover, although the trial court heard testimony that the foster parents were interested in adopting the children if LCCS was granted permanent custody, that potential adoption was not a focus of the trial court’s permanent custody decision. The trial court’s best interest determination was guided by specific statutory factors, which do not include the child’s probability of being adopted.

Section 2151.414(D)(1)(a)’s interaction-and-interrelationship factor requires the court to consider the child’s relationship with siblings.

In re J.B. · filed 2013-12-26(D)(1)(a)

When determining whether a grant of permanent custody is in a child’s best interest, the juvenile court must consider all the relevant factors, including those enumerated in R.C. 2151.414(D): the interaction and interrelationships of the child, the wishes of the child, the custodial history of the child, and the child’s need for permanence in his life. ... Furthermore, the sibling relationship was properly considered by the trial judge as part of the first best interest factor, as it should be. See In re T.R., 9th Dist. Summit Nos. 25179 and 25213, 2010-Ohio-2431, ¶ 19.

A permanent-custody best-interest determination may be upheld when the court considers and weighs every statutory factor, including the effect of permanent custody on sibling relationships, and its findings are supported by the record.

In re K.B. · filed 2014-08-20(D)(1)

We have carefully reviewed the evidence in this case and find that the trial court's findings are supported by the record. The trial court considered and weighed the evidence in light of each of the factors, including the effect of granting permanent custody on the sibling relationship, and in a thorough decision made findings that are supported by the record.

Potential legal separation from biological siblings does not preclude permanent custody when the adoptive families' established practice supports continued contact.

In re Z.C. · filed 2022-09-09(D)(1)(a)

The families who have custody of six of Z.C.’s siblings have expressed a willingness to keep the children in contact. Though there was some concern expressed about their present ability to connect with Z.C., the record shows some contact between Z.C. and his siblings during the pendency of these proceedings. The juvenile court ultimately gave greater weight to the past practice of the adoptive families than Father’s promise of future behavior in keeping the family together.

Section 2151.414(D)(1)(a)'s relationship factor supported keeping children together where they had always lived together and were bonded to one another.

In re K.C. · filed 2025-01-15(D)(1)(a)

The trial court specifically found the Children have always lived together and are bonded to one another; therefore, should remain together wherever they go. ... We further find the trial court's finding it was in the Children’s best interest to grant permanent custody to ACJFS was not against the manifest weight of the evidence.

Subsections (D)(1) and (D)(2) are alternative best-interest tests; if any required (D)(2) circumstance is absent, the court must weigh the (D)(1) factors.

In re R.D. · filed 2022-12-15(D)(1), (D)(2)

If, however, any of the circumstances enumerated in R.C. 2151.414(D)(2) does not exist, then the juvenile court must proceed to a weighing of factors set forth in R.C. 2151.414(D)(1) to determine what is in the child’s best interest.

Unlike subsection (D)(1), subsection (D)(2)'s per se best-interest test does not expressly require consideration of the child's wishes.

In re AN.M. · filed 2022-08-18(D)(2)

Unlike the factors contemplated under R.C. 2151.414(D)(1), section (D)(2) does not expressly require the court to consider the wishes of the child.

When all four subsection (D)(2) findings are present, permanent custody is in the child's best interest as a matter of law and no separate weighing under subsection (D)(1) is necessary.

In re T.L. · filed 2021-09-16(D)(2)

When the juvenile court makes the four enumerated findings under R.C. 2151.414(D)(2), permanent custody is in the child's best interest, as a matter of law, and the court shall commit the child to the permanent custody of the agency.

Subsection (D)(2) is only an alternative route to a best-interest finding, so adequate findings under subsection (D)(1) eliminate any need to apply subsection (D)(2).

In re T.P. · filed 2018-04-09(D)(1), (D)(2)

Further, “R.C. 2151.414(D)(2) ... applies only as an alternative basis for the trial court to determine that the termination of parental rights is in the best interest of the children.” ... When there are sufficient grounds under the factor analysis found in R.C. 2151.414(D)(1), as outlined below, the trial court need not resort to R.C. 2151.414(D)(2) to determine whether permanent custody is in the children’s best interests.

When all four subsection (D)(2) factors apply, the court must find permanent custody is in the children’s best interest and grant permanent custody without also applying subsection (D)(1).

In re J.L. · filed 2018-05-29(D)(2)

Since the trial court found that each of the four factors in R.C. 2151.414(D)(2) applies, the court was required to find that permanent custody is in the best interests of the children and to grant permanent custody. Although the trial court correctly stated that a trial court is not required to apply both best-interest tests in R.C. 2151.414(D)(1) and (D)(2), H.C., supra, the court also made the findings required under R.C. 2151.414(D)(1).

Subsection (D)(2) is an alternative route to a best-interest determination, not a prerequisite to awarding permanent custody under subsection (D)(1).

In re C.J. · filed 2017-11-17(D)(2)

However, mother’s reliance on R.C. 2151.414(D)(2) is misplaced. R.C. 2151.414(D)(2), instead of being a requirement for awarding permanent custody, is an “alternative to reaching the best interest determination through the factors in R.C. 2151.414(D)(1).”

When all subsection (D)(2) factors apply, permanent custody is in the child’s best interest and the court need not separately weigh the subsection (D)(1) factors.

In re C.L. · filed 2017-08-11(D)(2)

The trial court found that R.C. 2151.414(D)(2) controlled the outcome of this case. Mother’s sole assignment of error contends that, even when R.C. 2151.414(D)(2) is used to determine the child’s “best interest,” there still must be a “best interest” analysis using the R.C. 2151.414(D)(1)(a)-(e) factors. However, “[i]f all of the R.C. 2151.414(D)(2) factors apply, ‘then an award of permanent custody is in the child’s best interest, and the trial court need not perform the weighing specified in division (D)(1).’ ”

Section 2151.414(D)(2)’s mandatory best-interest determination applies only when all four listed conditions exist; if any is absent, the court must weigh the factors in subsection (D)(1).

In re H.C. · filed 2013-12-31(D)(2)

As we understand division (D)(2), if all of the facts enumerated therein apply, then an award of permanent custody is in the child's best interest, and the trial court need not perform the weighing specified in division (D)(1). But if it is not the case that all of the facts enumerated in division (D)(2) exist; that is, if any one of the facts enumerated in division (D)(2) does not exist, then the trial court must proceed to the weighing of factors set forth in division (D)(1) to determine the child's best interest. ... Here the trial court should not have discussed the R.C. 2151.414(D)(2) test. Because the children were only in appellee’s custody for 14 months at the time of the hearing, the (D)(2) test did not apply. ... The court’s reference to the R.C. 2151.414(D)(2) was superfluous.

When comparing permanent custody to an agency with legal custody to a relative, the court conducts a single best-interest review under the statutory factors because a finding that permanent custody is in the children's best interests necessarily rules out legal custody to the relative.

In re S.P. · filed 2014-03-26(D)(1)

Because the trial court’s decision whether to place the children in the legal custody of Grandmother was also based on the best interest of the children, “this Court typically conducts a single ‘best interest’ review of the trial court’s decision to place the child[ren] in the permanent custody of the agency rather than in the legal custody to a relative.” ... If permanent custody is in the children’s best interest, legal custody to Grandmother necessarily is not. “‘Consequently, this Court will review the factors set forth in R.C. 2151.414(D) in reviewing the [best interest] decision of the trial court * * *.’”

When every condition in R.C. 2151.414(D)(2) is met and no practical alternative to permanent agency placement exists, the legislature has determined that the child should not remain in legal limbo and the agency should proceed with permanent placement.

In re B.B. · filed 2015-09-18(D)(2)

Division (D)(2) provides that if: (a) the trial court has determined, by clear and convincing evidence, that the child cannot be placed with either parent within a reasonable time, or should not be placed with either parent; and (b) the child has been in the agency's custody for two years or longer and no longer qualifies for temporary custody; and (c) the child does not meet the requirements for a planned permanent living arrangement; and (d) no one has come forward to seek legal custody of the child, then, in that case, where there is no practical alternative to a permanent placement by the agency, the General Assembly has made a legislative determination that it is not in the best interest of the child to remain in legal limbo—the agency should be allowed to move forward with a permanent placement for that child.

A permanent-custody award satisfies subsection (D)(1)'s best-interest requirement when the record supports the trial court's best-interest determination.

In re I.S. · filed 2019-11-06(D)(1)

Accordingly, upon review of the record before us, we find no basis to overturn the decision of the trier of fact, and we conclude the grant of permanent custody of I.S. was made in the consideration of the child's best interests and did not constitute an error or an abuse of discretion.

After a child is found abandoned, Section 2151.414 requires the court to determine whether permanent custody is in the child's best interest.

In re L.C. · filed 2023-03-10(B)(1)(b), (D)(1)

Because the children had been abandoned, the trial court’s next and final determination was whether a grant of permanent custody to the agency was in the children’s best interest.

Former subsections (D)(1) and (D)(2) provided alternative best-interest paths: all subsection (D)(2) circumstances mandated permanent custody, while subsection (D)(1) required weighing multiple factors.

In re A.S. · filed 2025-05-14former (D)(1) and (D)(2)

As we have explained, former R.C. 2151.414(D)(1) and 2151.414(D)(2) were alternative means for reaching the best-interest determination. ... Former R.C. 2151.414(D)(2) set forth a list of circumstances that, if all were found to exist, mandated a finding that permanent custody was in the best interest of the child. ... In contrast, under former R.C. 2151.414(D)(1), the juvenile court was required to weigh multiple factors ‘to decide whether granting an agency permanent custody of a child is in that child’s best interest.’

Subsections (D)(1) and (D)(2) are alternative ways to establish best interest, so a court finding best interest under subsection (D)(1) need not also analyze subsection (D)(2).

In re N.B. · filed 2025-08-07(D)(1) and (D)(2)

R.C. 2151.414(D)(1) and 2151.414(D)(2) are ‘alternative means’ for determining whether permanent custody is in a child’s best interest. ... Thus, a juvenile court need not conduct an R.C. 2151.414(D)(2) analysis if it determines that permanent custody is in the child’s best interest under R.C. 2151.414(D)(1).

When all subsection (D)(2) factors apply, permanent custody is mandatorily in the child's best interest and the court must commit the child to the agency.

In re S.M. · filed 2025-11-13(D)(2)

Thus, clear and convincing evidence supported the juvenile court’s finding that all the R.C. 2151.414(D)(2) factors applied. A juvenile court’s determination that all of the R.C. 2151.414(D)(2)(a)-(d) factors apply mandates a finding that “permanent custody is in the best interest of the child, and the court shall commit the child to the permanent custody of [an agency].”

When all four subsection (D)(2) findings apply, permanent custody is per se in the child's best interest and the court must commit the child to the agency.

In re A.K. · filed 2026-05-14(D)(2)

If all the factors enumerated under R.C. 2151.414(D)(2) are applicable, permanent custody is per se in the child’s best interest and the juvenile court must commit the child to the permanent custody of the agency. ... Viewed collectively, the R.C. 2151.414(D)(2) findings mandated that permanent custody is in the children’s best interests and that the court commit the children to the permanent custody of the agency.

Section 2151.414(D) requires the court to consider the best-interest factors when deciding whether to grant an agency permanent custody.

In the Matter of Cabanas, Unpublished Decision (9-30-2002) · filed 2002-09-30(D)

Based on our review of the factors in R.C. 2151.414 (D) and all relevant evidence in the record, we find that there was clear and convincing evidence before the trial court that it was in the children's best interest that BCCSB be granted permanent custody.

When a child has been in agency custody for at least 12 of 22 consecutive months, the court determines permanent custody by considering the child's best interest under § 2151.414(D), without deciding whether the child can or should be placed with a parent within a reasonable time.

In Re Brown, Unpublished Decision (6-24-2004) · filed 2004-06-24(D)

When, as here, a child has been in the custody of FCCS for 12 or more months of a consecutive 22-month period, a trial court need not engage in an analysis of whether the child can or should be placed with either parent within a reasonable time. Instead, the consideration in such a case is the best interest of the child, which is determined by consideration of the factors set forth in R.C. 2151.414 (D) in light of the facts of the particular case.

Section 2151.414(D) requires clear and convincing evidence that permanent custody is in the child's best interest and consideration of the listed best-interest factors.

In Re B.N., Unpublished Decision (8-26-2004) · filed 2004-08-26(D)

In considering an award of permanent custody, the court must first determine whether, by clear and convincing evidence, it is in the best interest of the child to grant permanent custody. R.C. 2151.414 (D). In determining the best interest of the child during the permanent custody hearing, the court must consider the factors listed in R.C. 2151.414 (D), which include the reasonable probability the child will be adopted, the interaction of the child with the child's parents, siblings, and foster parents, the wishes of the child, the custodial history of the child, and the child's need for a legal secure permanent placement.

Section 2151.414(D)(1) permits an award of permanent custody when it serves the child’s best interest, even if a parent has complied with parts of the case plan.

In re F.T. · filed 2023-01-12(D)(1)

Thus, a parent’s case plan compliance will not preclude a trial court from awarding permanent custody to a children services agency when doing so is in the child’s best interest.

A 12-of-22-month finding has no effect when the agency did not invoke subsection (B)(1)(d) and instead sought to prove other threshold grounds.

In re Baby Boy N. · filed 2021-04-13(B)(1)(d)

Thus, even if H.B. had properly objected to the magistrate's finding and not waived his challenge to it, the finding had no effect on the case FCCS had to prove.

A juvenile court may not base a reasonable-time placement finding on a Section 2151.414(E) ground that the agency did not allege in its permanent-custody motion.

In re K.C. · filed 2018-06-18(E)(4)

LCCS did not allege Mother’s lack of commitment pursuant to R.C. 2151.414(E)(4). Accordingly, the juvenile court improperly based its finding, in part, on a ground not alleged by the agency. ... This does not end the inquiry, however, as the agency’s motion for permanent custody gave Mother notice of its first-prong allegation based on both R.C. 2151.414(E)(1) and (2).

A court may rely on abandonment under subsection (B)(1)(b) even when the permanent-custody motion identifies another statutory ground, provided abandonment was timely brought to the parent's attention and the parent was prepared to rebut it.

In re K.G. · filed 2014-01-21(B)(1)(b)

In granting a motion for permanent custody, a trial court may not rely upon a ground unless that ground has been properly brought to the attention of the parents in a timely fashion. ... The record reflects that abandonment as a potential basis for permanent custody was properly brought to appellant’s attention in a timely fashion, such that she was prepared to attempt to rebut appellee’s evidence of abandonment.

Because Section 2151.414(B)(1)(a) states the cannot-be-placed and should-not-be-placed alternatives disjunctively, counsel receiving notice under that provision must prepare to defend either alternative.

In re J.M. · filed 2014-08-07(B)(1)(a)

CCDJFS counters both of these options are contained within the same statutory section, R.C. 2151.414(B)(1)(a), which is clearly written in the disjunctive. ... Second, given the manner in which the statute is written, Jennifer's counsel had to prepare to defend either option.

Subsection (B)(1) contains the grounds for permanent custody, while subsection (E) supplies alternative factors for deciding whether the subsection (B)(1)(a) cannot-or-should-not-be-placed ground exists.

In re J.H. · filed 2025-06-26(B)(1)(a), (E)

The mother’s argument conflates the factors in division (E) with the “grounds” for a permanent custody motion. ... As can be seen in the language employed in the Supreme Court case she cites, it is division (B)(1) that contains the “grounds” for a permanent custody motion. ... In contrast, division (E) essentially contains alternative “factors” for determining whether the court is required to conclude the (B)(1)(a) ground exists.

The court may consider a parent's lack of visitation in the statutory best-interest analysis even when visitation was not a formal case-plan objective.

In re A.C. · filed 2014-10-03(D)(1)(a)

As for Father’s arguments, the fact that “visitation” was not identified as a formal case-plan objective does not mean the trial court could not consider his lack of visitation when considering A.C.’s best interest.

A child's therapist may provide relevant evidence under Section 2151.414(D)(1)(a) when the testimony bears on the interaction and interrelationship between parent and child.

In re M.S. · filed 2014-07-21(D)(1)(a)

Fox’ testimony regarding visitation between Swank and the minor child was relevant as evidence of the “interaction and interrelationship” between mother and child, a necessary consideration in evaluating the best interests of the child. R.C. 2151.414(D)(1)(a). Although Fox testified that she did not believe that Swank should have visitation with the child, this testimony was more akin to factual testimony rather than expert opinion testimony. Swank’s visitation with the child interfered with the child’s own therapy and hindered Fox’ efforts to address the child’s sexual abuse issues. Accordingly, it related to the child’s best interests and was not a recommendation regarding the ultimate custodial issue.

Under subsection (D)(1)(a), a court may compare a child's interactions and relationships with a parent and foster family, and appropriate interaction with the parent is not controlling when the child interacts better and has a better relationship with the foster family.

In re J.G. · filed 2014-02-14(D)(1)(a)

Upon review, we see no abuse of discretion in the trial court’s finding that an award of permanent custody to MCCS is in J.G.’s best interest. Although Mother interacts appropriately with J.G., the evidence demonstrates that the child interacts better, and has a better relationship, with the foster family. This is understandable given the child’s long-term placement in foster care. Nevertheless, J.G.’s interaction with Mother and the foster family is a relevant best-interest consideration.

Evidence that children are thriving, bonded to foster parents, receiving needed specialized care, and likely to be adopted supports the relationship factor favoring permanent custody.

In re F.F. · filed 2023-11-17(D)(1)(a)

Unrefuted evidence was presented to the trial court demonstrating that the minor children are thriving in their foster home, are bonded to the foster parents, have successfully been in this foster home for the majority of their lives, are receiving needed specialized care from the foster parents, and the foster parents would like to adopt both of the children. The record establishes R.C. 2151.414(D)(1)(a) evidence favoring the best interest of the child determination.

A court considering a child's wishes under § 2151.414(D)(1)(b) is limited to wishes expressed directly by the child or through the child's guardian ad litem and may not rely on other sources.

In re H.M. · filed 2014-03-03(D)(1)(b)

These wishes must be “expressed directly by the child or through the child’s GAL, with due regard for the maturity of the child.” Id. Thus, trial courts are limited, when investigating the wishes of the child, to the testimony of the GAL or the child, and may not consider testimony from other sources.

Section 2151.414(D)(1)(b) permits a court to weigh a mature child's clearly expressed wish for adoption in deciding permanent custody.

In re K.S. · filed 2023-05-23(D)(1)(b)

Given K.S.’s age and maturity level, the trial court did not err in its consideration of R.C. 2151.414(D)(1)(b) when listening to K.S.’s clearly expressed wishes and weighing them in its decision to grant the motion for permanent custody.

A trial court may accept a guardian ad litem's account of a child's wishes instead of directly interviewing the child.

In re R.C. · filed 2025-11-13(D)(1)(b)

The statute unambiguously gives the trial court the choice of considering the child's wishes directly from the child or through the guardian ad litem. ... The trial court has discretion to accept testimony of the guardian ad litem on the child's wishes rather than hearing a direct expression of those wishes made by the child.

A court may consider a child's wishes directly or through the guardian ad litem's report, with due regard for the child's maturity.

In re V.T. · filed 2026-01-05(D)(1)(b)

The statute expressly authorizes the court to consider a child's wishes "with due regard for the maturity of the child." ... The court may consider the child's wishes either directly or through the GAL's report.

The subsection (D) best-interest factors do not specifically require an in-camera interview concerning a child's wishes in a legal-custody proceeding.

In re A.B. · filed 2026-02-23(D)(1)

The best interest considerations relating to permanent custody determinations in R.C. 2151.414(D) do not make any specific reference to in camera interviews of children regarding their wishes.

Section 2151.414 lets a juvenile court consider a child's wishes either directly from the child or through the guardian ad litem.

In re X.P. · filed 2026-03-25(D)(1)(b)

R.C. 2151.414 “unambiguously gives the trial court the choice of considering the child’s wishes directly from the child or through the guardian ad litem”

Sections 2151.414(E)(5), (E)(7)(d), and (E)(12) support a finding against placement with a parent serving a lengthy prison term for sexually abusing the children’s sibling.

In re A.S. · filed 2013-09-11(E)(5), (E)(7)(d), and (E)(12)

The overwhelming evidence clearly mitigated against appellant's involvement in the rearing of his children as he was found guilty of sexually abusing the children's step-sibling in his care. R.C. 2151.414(E)(5), (7)(d), and (12).

When a parent has a qualifying conviction under Section 2151.414(E)(6), the court must find that the child cannot or should not be placed with that parent within a reasonable time.

In re A.C. · filed 2023-03-23(E)(6)

Additionally, pursuant to R.C. 2151.414(E)(6), the record supported the juvenile court’s finding that the children’s parents pleaded guilty to multiple violations of R.C. 2919.21(A). Because of these convictions, the juvenile court was required to find that the children cannot or should not be placed with either parent within a reasonable time.

Under subsection (B)(1)(a), a child may be found unable to return to either parent when one parent poses a safety danger and the other would rely on that parent for care.

In the Matter of M.L.J., Unpublished Decision (8-19-2004) · filed 2004-08-19(B)(1)(a)

Moreover, given her husband's working hours and inclination to allow appellant to care for their child, the trial court reasonably could conclude by clear and convincing evidence that the child could not be returned to appellant or her husband, as appellant posed a danger to the child with her explosive personality, and her husband persisted in his belief that M.L.J. would be safe with appellant.

Under subsection (E), completion of case-plan tasks does not preclude a cannot-be-placed finding when all relevant evidence shows that unresolved parenting conditions make returning the children dangerous.

In re C.B. · filed 2013-11-08(E)

Under R.C. 2151.414(E), the trial court must consider all relevant evidence before making this determination. ... Schwartz expressed concerns about the children being returned to Parents’ home because the likelihood Mother would revert to her old behaviors was high. Mother needed to be accountable for her actions. ... Based upon the foregoing, we find the trial court's findings the children could not be placed with Parents within a reasonable time, and an award of permanent custody was in the best interest of the children were not against the manifest weight of the evidence and were based upon sufficient evidence.

Division (C) prohibits denying permanent custody solely because the agency failed to implement a particular part of the child's case plan.

In re L.B. · filed 2020-05-21(C)

Similarly, R.C. 2151.414(C) prohibits a court from "deny[ing] an agency's motion for permanent custody solely because the agency failed to implement any particular aspect of the child's case plan."

A court may not deny permanent custody solely because the agency failed to implement one particular aspect of the child’s case plan.

In re L.G. · filed 2022-02-24(C)

As a general matter, a court is not entitled to deny an agency’s request for permanent custody of a child solely because the agency failed to implement one aspect of a case plan. Cf. R.C. 2151.414(C) (“The court shall not deny an agency's motion for permanent custody solely because the agency failed to implement any particular aspect of the child's case plan.”).

A parent's compliance with a case plan does not bar permanent custody when awarding custody to the agency is in the child's best interest.

In re E.R. · filed 2023-04-25(D)(1)(d)

Thus, a parent’s case plan compliance will not preclude a trial court from awarding permanent custody to a children services agency when doing so is in the child’s best interest. Id.

Completing a case plan does not establish reunification when the parent has not substantially remedied the conditions that caused removal.

In re M.A.P. · filed 2023-05-24(A)(1)

A parent’s successful completion of the terms of a case plan is not dispositive on the issue of reunification. The ultimate question under R.C. 2151.414(A)(1) is whether the parent has substantially remedied the conditions that caused the child’s removal.

Permanent custody under Section 2151.414(D)(1) turns on the children's best interests rather than technical case-plan compliance, so discontinuing counseling carries little weight without proof that continued counseling is necessary for those interests.

In re G.C.M.G. · filed 2023-08-25(D)(1)

As noted above, permanent custody proceedings are not a test of compliance with the case plan but a determination of the children’s best interests. Failure to continue with counseling, when it is not proven necessary to further the best interests of the children, is of little consequence.

Participation in case-plan services does not require returning children to a parent when evidence shows that doing so would cause the children further trauma.

In re B.H. · filed 2024-02-07(D)

The trial court was not bound to return the children to mother simply because she had participated in services when there was evidence that doing so would cause the children more trauma.

Participation in case-plan services does not remedy removal conditions when the parent shows no improvement in the ability to parent appropriately.

In re X.S.R.S. · filed 2024-04-29(E)(1)

Although Mother has participated in case-plan services, there seems to be no improvement in her ability to parent the children appropriately.

Successful completion of some case-plan services does not preclude permanent custody when the parent has not demonstrated significant progress or benefit from those services.

In re N.C. · filed 2025-06-05(D)(1)

Even though father completed certain case-plan services, as the juvenile court determined, he failed to demonstrate significant progress or a benefit from those services. Indeed, a parent’s successful completion of a case plan does not preclude a grant of permanent custody to a social services agency.

Completing case-plan requirements does not preclude permanent custody when the parent has not substantially remedied the conditions that caused removal; the plan is a means, not the goal.

In re A.S. · filed 2025-07-21(E)(1)

A parent can successfully complete the terms of a case plan yet not substantially remedy the conditions that caused the children to be removed—the case plan is simply a means to a goal, but not the goal itself. Hence, the courts have held that the successful completion of case plan requirements does not preclude a grant of permanent custody to a social services agency.

Subsection (E)(1) asks whether the parent remedied the conditions that caused removal, not merely whether the parent substantially complied with a case plan.

In re Z.H. · filed 2025-07-24(E)(1)

Although Father is commended for his efforts to remain sober and completing most of his case plan, under R.C. 2151.414(E)(1), the issue is not whether Father substantially complied with the case plan, but whether Father remedied the conditions that caused the child’s removal. ... Father clearly did not.

Substantial case-plan compliance is relevant to best interest but is not dispositive.

In re D.R.-S. · filed 2025-08-14(D)

This court has held that “ ‘while evidence of case plan compliance is relevant to a best-interest determination, it is not dispositive of it.’ ”

A parent's compliance with a case plan is relevant to the statutory best-interest factors but is not dispositive of the child's best interest.

In re S.G. · filed 2025-09-30(D)

This Court reiterates our long-held proposition of law that, while a parent’s case plan compliance is relevant to the best interest of the child, it is not dispositive of the issue. ... We focus our review on the above-listed R.C. 2151.414(D) best interest factors, which take into consideration a parent’s case plan progress.

Completion of some case-plan requirements does not establish compliance when the parent cannot apply what was taught and has gaps in other services.

In re H.B. · filed 2025-11-10(D)(1)

While Mother argues that she has successfully completed her case plan objectives, the clear and convincing evidence demonstrates otherwise. Although she completed her parenting classes, Mother struggled to apply the lessons during her visits with H.B. While she engaged in counseling, there were gaps in her participation.

Case-plan progress is not dispositive of a child's best interest.

In re D.B. · filed 2026-02-25(D)(1)

Moreover, the record does not support Mother’s assertions that she had made significant progress on the reunification requirements of the case plan.

Case-plan compliance is relevant to whether the child needs a legally secure permanent placement but is not dispositive of the best-interest inquiry.

In re C.A. · filed 2026-06-17(D)(1)(d)

Although case plan compliance is relevant to the best interest of the child, this Court has repeatedly recognized that it is not dispositive of that issue.

The likelihood of adoption may inform the best-interest analysis, but an agency need not prove adoption is likely, and the absence of that likelihood does not preclude a permanent-custody award.

In re V.B.-S. · filed 2013-12-12(D)(1)(d)

But the statutes contemplate that all of the statutory best-interest factors must be considered and, although the likelihood of adoption weighs in favor of such an award, the absence of that likelihood does not preclude the court from finding that an award of permanent custody is in the child's best interest.

An agency need not prove adoption is likely before permanent custody may be found in a child's best interest; adoption likelihood is one factor, and its absence does not preclude permanent custody.

In re H.F. · filed 2016-02-18(D)(1)(d)

While it “is true that the likelihood that a child will be adopted may be considered in determining the child's best interest[,] * * * the statutes contemplate that all of the statutory best-interest factors must be considered and, although the likelihood of adoption weighs in favor of such an award, the absence of that likelihood does not preclude the court from finding that an award of permanent custody is in the child's best interest.”

Although Section 2151.414(D) does not require consideration of adoption likelihood, a court may consider it when the circumstances make adoption relevant.

In re G.H. · filed 2016-03-22(D)

Although nothing in R.C. 2151.414(D) requires a juvenile court to consider the likelihood of adoption, a juvenile court may include that consideration in its analysis if the circumstances of a particular case render it a relevant.

Permanent custody is not precluded merely because the child's existing placement is not foster-to-adopt.

In re E.K. · filed 2016-07-22(D)(1)(d)

In addition, the fact that E.K.’s existing placement was not foster-to-adopt did not preclude awarding permanent custody to MCCS.

Section 2151.414(D)(1)(d) does not require concrete proof that the child will be adopted; lack of a likely adoption does not bar a best-interest finding for permanent custody.

In re A.M. · filed 2024-08-08(D)(1)(d)

Indeed, “R.C. 2151.414(D)(1)(d) does not require a ... children services agency ‘to present concrete proof that the child will be adopted if the court awards the agency permanent custody.’ ” ... Specifically, the Supreme Court of Ohio recognized that, “while a juvenile court reviewing a motion for permanent custody was at one time required to consider the child’s probability of being adopted, [. . .] the current statutory framework does not expressly require the court to consider this information in making a best-interest determination.”

A good parent-child relationship alone is insufficient because best interests also require permanency and a safe, secure environment.

In re J.S. · filed 2022-12-15(D)(1)(a)

There was testimony that Mother and J.S. had a good relationship; however, this court has recognized that the best interest of the child requires permanency and a safe, secure environment, and the mere existence of a good relationship is insufficient.

A bond between parent and child does not preclude a best-interest finding in favor of permanent custody when the other statutory factors outweigh that bond.

In re S.D. · filed 2014-01-17(D)(1)(a)

However, the court carefully addressed these arguments in its decision and the court's findings are supported by the record. Although the court found there was a bond between appellant and child, the court determined that the best interest factors weighed in favor of granting permanent custody. In addition, as discussed above, the court addressed the reasons why appellant was not able to provide a legally secure placement.

The absence of any parent-child bond or visits may make the harm of terminating that nonexistent bond substantially outweighed by the benefit of permanence and stability.

In re K.R. · filed 2016-02-09(D)(1)

The trial court found the harm of breaking this nonexistent bond is far outweighed by the benefit of permanency and stability in K.R.’s life and we agree.

A child's interest in permanency may outweigh the detriment of severing an existing parent-child bond when the parent has not shown an ability to meet the child's needs consistently.

In re Z.B.C. · filed 2016-04-18(D)(1)(d)

The trial court recognized that Appellant and Z.B.C. shared a bond. However, the court found that the child’s interest in permanency outweighed the detriment of severing this bond.