In re A.R.B.

2024 Ohio 4830
CourtOhio Court of Appeals
DecidedOctober 7, 2024
DocketCA2024-04-057; CA2024-04-058; CA2024-04-059; CA2024-05-066
StatusPublished
Cited by2 cases

This text of 2024 Ohio 4830 (In re A.R.B.) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re A.R.B., 2024 Ohio 4830 (Ohio Ct. App. 2024).

Opinion

[Cite as In re A.R.B., 2024-Ohio-4830.]

IN THE COURT OF APPEALS

TWELFTH APPELLATE DISTRICT OF OHIO

BUTLER COUNTY

IN RE: :

A.R.B., et al. : CASE NO. CA2024-04-057 CA2024-04-058 : CA2024-04-059 CA2024-05-066 : OPINION : 10/7/2024

:

APPEAL FROM BUTLER COUNTY COURT OF COMMON PLEAS JUVENILE DIVISION Case No. JN2022-0024; JN2022-0025; JN2022-0087

Fred S. Miller, for mother.

Mark W. Raines, for grandmother.

Garrett Law Offices, and Dawn S. Garrett, for children.

CASA, and Sarah A. Owens, guardian ad litem.

Michael T. Gmoser, Butler County Prosecuting Attorney, and Michael Greer, Assistant Prosecuting Attorney, for appellee.

M. POWELL, J.

{¶ 1} Kayla Brown ("Mother") and Christy Brown ("Grandmother") appeal the Butler CA2024-04-057 thru 059 CA2024-05-066

decision of the Butler County Court of Common Pleas, Juvenile Division, granting

permanent custody of seven-year-old Alice, five-year-old Beth, and four-year-old Charles

(collectively, the "children") to the Butler County Department of Jobs and Family Services

("the Agency").1 For the reasons outlined below, we affirm the juvenile court's decision.

{¶ 2} At first glance, the facts of this case are bewildering. They involve the three

children subject to these proceedings, other children not subject to these proceedings,

criminal proceedings, and the lurid relationships between multiple generations of family

members. However, many of the underlying facts are not contested in any significant

way or are clearly established in the record.

{¶ 3} The Agency filed complaints regarding Alice and Beth on January 27, 2022.

Alice and Beth had been in Grandmother's legal custody since 2019 after prior custody

proceedings removed them from Mother's care. The complaints alleged that Alice and

Beth were dependent children because Jesse Black, Grandmother's paramour, was

arrested for domestic violence involving Grandmother and because Black used cocaine

with and later assaulted one of his and Grandmother's children.

{¶ 4} The complaints further stated that Alice and Beth were confirmed via

paternity tests to be Black's children. That is, Black engaged in a sexual relationship with

Mother, who is Grandmother's daughter. Mother was a minor when she gave birth to

Alice and Beth, and because of this, Black was later convicted of two counts of gross

sexual imposition and one count of unlawful sexual conduct with a minor. Black was

incarcerated during the custody proceedings below and remains incarcerated.

{¶ 5} The Agency also filed a complaint regarding Charles on March 22, 2022

1. Alice, Beth, and Charles are pseudonyms adopted for this opinion for the purposes of privacy and readability. In re D.P., 2022-Ohio-4553, ¶ 1, fn. 1 (12th Dist.). -2- Butler CA2024-04-057 thru 059 CA2024-05-066

after Mother was arrested for domestic violence against a sibling in Grandmother's home

while Charles was present. Charles was in Mother's custody, and it was alleged Mother

could not provide stable housing or support for him. Charles was also confirmed to be

Black's biological child.

{¶ 6} The court granted temporary custody of Alice, Beth, and Charles to the

Agency in September 2022. In July 2023, the Agency moved for permanent custody of

the children, and after conducting a hearing, the magistrate granted the Agency's motion.

Mother and Grandmother filed objections to the magistrate's decision, but the trial court

overruled the objections and adopted the opinion of the magistrate.

{¶ 7} Further facts will be discussed below.

{¶ 8} On appeal, Mother and Grandmother generally raise two similar

assignments of error.

{¶ 9} MOTHER'S FIRST ASSIGNMENT OF ERROR AND GRANDMOTHER'S

SECOND ASSIGNMENT OF ERROR:

{¶ 10} THE TRIAL COURT ERRED TO THE PREJUDICE OF MOTHER WHEN IT

DID NOT INQUIRE OF EACH PARTICIPANT IN THE CASE WHETHER HE OR SHE

KNEW OR HAD REASON TO KNOW WHETHER EACH CHILD IS AN INDIAN CHILD.

{¶ 11} THE TRIAL COURT FAILED TO COMPLY WITH THE INDIAN CHILD

WELFARE ACT BEFORE ISSUING ITS DECISION GRANTING PERMANENT

CUSTODY.

{¶ 12} First, both Mother and Grandmother argue the trial court should be reversed

because it failed to comply with the requirements of the Indian Child Welfare Act (the

"Act") as found in 25 U.S.C. 1911.

{¶ 13} The parties agree that three separate inquiries were made regarding

-3- Butler CA2024-04-057 thru 059 CA2024-05-066

whether the children have Indian heritage. Two occurred at ex parte hearings with neither

Mother nor Grandmother present on March 22, 2022 and August 25, 2022. At each, the

magistrate asked if there was any possibility that Charles is an Indian child, and the

caseworker responded there was not at each hearing. At the March 22 hearing, the

magistrate also asked, and the Agency confirmed, that the Agency had inquired as to

whether Charles is an Indian child. The magistrate's entries after each hearing stated the

Act was complied with and that Charles was not an Indian child.

{¶ 14} On March 30, 2022, both Mother and Grandmother were present for a

shelter care hearing when the magistrate asked "does anybody have any reason to

believe that [Charles] is a member of a Native American Tribe, an Indian Tribe or is eligible

for membership in an Indian Tribe or if either of [Charles's] parents is a member of an

American Tribe or is eligible for membership?" After the Agency replied no, the

magistrate stated, "No, okay, alright. I think that clears up what federal laws are involved

right now." The magistrate's entry after this hearing also stated the Act was complied

with and that Charles was not an Indian child.

{¶ 15} The Act is a federal law that requires state courts to inquire of "each

participant in an emergency or voluntary or involuntary child-custody proceeding" whether

there is any reason to believe the children involved are a member of or eligible for

membership in an Indian tribe. 25 C.F.R. 23.107(a) and 23.2. If there is, various

procedural requirements exist within the Act which "aim[ ] to keep Indian children

connected to Indian families." Haaland v. Brackeen, 599 U.S. 255, 255 (2023). Failure

by Ohio courts "to identify Indian children can nullify court proceedings that have not been

conducted in accordance with [the Act]." Adm.Code 5101:2-53-02.

{¶ 16} We note at the onset that because Grandmother and Mother did not raise

-4- Butler CA2024-04-057 thru 059 CA2024-05-066

issues regarding the Act at the trial level, they have forfeited all but plain error. Doran v.

Doran, 2009-Ohio-5521, ¶ 15 (12th Dist.). A party asserting plain error must show an

obvious error by the trial court that affects that party's "substantial rights." State v. Rogers,

2015-Ohio-2459, ¶ 22. Stated differently, plain errors "'must have affected the outcome

of the trial.'" Id., quoting State v. Barnes, 94 Ohio St.3d 21, 27 (2002); see also State v.

Biros, 78 Ohio St.3d 426 (1997) ("Plain error does not exist unless it can be said that but

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2024 Ohio 4830, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-arb-ohioctapp-2024.