In re C.A. Children

2020 Ohio 5243
CourtOhio Court of Appeals
DecidedNovember 10, 2020
DocketC-200172
StatusPublished
Cited by2 cases

This text of 2020 Ohio 5243 (In re C.A. Children) 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 C.A. Children, 2020 Ohio 5243 (Ohio Ct. App. 2020).

Opinion

[Cite as In re C.A. Children, 2020-Ohio-5243.]

IN THE COURT OF APPEALS FIRST APPELLATE DISTRICT OF OHIO HAMILTON COUNTY, OHIO

IN RE: C.A. CHILDREN : APPEAL NO. C-200172 TRIAL NO. F19-0770Z :

: O P I N I O N.

Appeal From: Hamilton County Juvenile Court

Judgment Appealed From Is: Affirmed

Date of Judgment Entry on Appeal: November 10, 2020

Tibbs Law Office, LLC, and Daryle C. Tibbs, for Appellant Father,

Joseph T. Deters, Hamilton County Prosecuting Attorney, and Alyssa Miller, Assistant Prosecuting Attorney, for Appellee Hamilton County Department of Job and Family Services,

Raymond T. Faller, Hamilton County Public Defender, and Megan E. Busam, Assistant Public Defender, Guardian ad Litem for the children. OHIO FIRST DISTRICT COURT OF APPEALS

MYERS, Presiding Judge.

{¶1} Father challenges the Hamilton County Juvenile Court’s judgment

adjudicating one of his children abused, neglected, and dependent, and two of his

children dependent. The child’s guardian ad litem (“GAL”) and the Hamilton County

Department of Job and Family Services (“HCJFS”) ask this court to affirm the

juvenile court’s judgment. Mother of the children has not appealed.

I. Background and Procedural History

{¶2} Father has three children with mother. In May 2019, their 13-year-old

daughter, LCA, disclosed at school that she had been sexually and physically abused

by father. LCA was transported from her school to the Mayerson Center at

Children’s Hospital, where she was interviewed by a social worker.

{¶3} HCJFS received interim custody of LCA and her brothers, aged 12 and

seven, and filed a complaint for temporary custody, alleging that the children were

abused, neglected, and dependent.

{¶4} Prior to the adjudication hearing, father and mother filed motions in

limine regarding LCA’s interview at the Mayerson Center. The magistrate denied the

motions, adjudicated LCA abused, neglected, and dependent, and awarded

temporary custody to HCJFS. The magistrate adjudicated the boys, OCA and JCA,

dependent, and placed them into the protective supervision of HCJFS. Thereafter,

the juvenile court overruled father’s objections and adopted the magistrate’s

decision. Father now appeals.

II. The Mayerson Center Interview

{¶5} In his first assignment of error, father argues that the juvenile court

erred by denying his motion in limine and allowing witnesses to testify about LCA’s

Mayerson Center interview and by allowing the Mayerson Center report into

2 OHIO FIRST DISTRICT COURT OF APPEALS

evidence. He argues that the evidence was hearsay and was not admissible under the

exception in Evid.R. 803(4) for statements made for purposes of medical diagnosis

or treatment.

{¶6} First, we point out that a motion in limine “is tentative and

precautionary in nature, reflecting the [trial] court’s anticipatory treatment of an

evidentiary issue at trial.” Defiance v. Kretz, 60 Ohio St.3d 1, 4, 573 N.E.2d 32

(1991). Therefore, a trial court’s disposition of a motion in limine such as the one in

this case is ultimately irrelevant because the trial court may change its ruling on the

disputed evidence when it is presented in context at trial, and the issue must be

revisited at trial to preserve the party’s position on the evidentiary issue. State v.

Morales, 1st Dist. Hamilton No. C-120670, 2014-Ohio-362, ¶ 45. Here, father

objected to the evidence at trial, thereby preserving the issue for appeal.

{¶7} At the adjudication hearing, the social worker from the Mayerson

Center testified that the purpose of the interview with LCA, as with any abuse-related

interview, was to assess LCA for medical or mental-health needs. After every such

interview, the social worker meets with a physician at the hospital to determine if a

child is in need of medical treatment or mental-health services.

{¶8} In the interview, LCA described acts of sexual and physical abuse and

identified the areas of her body that father had touched. At the suggestion of a

detective, the social worker used an anatomical drawing to clarify which parts of the

body the child was referring to. Because the child complained of pain and bleeding, a

physician examined her that day. In addition, because LCA reported that she was

suicidal, the social worker discussed with HCJFS the need for a safety plan and for

an assessment for mental-health services.

3 OHIO FIRST DISTRICT COURT OF APPEALS

{¶9} This court has held that statements made by a child victim to a social

worker at the Mayerson Center may be admissible under Evid.R. 803(4) as

statements for purposes of medical diagnosis or treatment. State v. Ridder, 1st Dist.

Hamilton No. C-150460, 2016-Ohio-5195, ¶ 7; State v. Bowers, 1st Dist. Hamilton

No. C-150024, 2016-Ohio-904, ¶ 20-24; State v. Lukacs, 188 Ohio App.3d 597,

2010-Ohio-2364, 936 N.E.2d 506, ¶ 8 (1st Dist.). In determining whether a child’s

statements were made for the purpose of medical diagnosis or treatment, the trial

court should consider (1) whether the child was questioned in a leading or suggestive

manner; (2) whether the child had a motive to lie, such as a pending custody battle;

(3) whether the child understood the need to tell the truth; (4) the child’s age; and

(5) whether the child’s statements were consistent. State v. Muttart, 116 Ohio St.3d

5, 2007-Ohio-5267, 875 N.E.2d 944, ¶ 49; State v. Williams, 2017-Ohio-8898, 101

N.E.3d 547, ¶ 11 (1st Dist.). The trial court has broad discretion to admit testimony

under this hearsay exception. Lukacs at ¶ 7; Muttart at ¶ 56.

{¶10} Here, the juvenile court specifically considered each of these factors

and determined that the child’s statement was made for the purpose of medical

diagnosis or treatment. The court noted the social worker’s testimony about her

training for conducting forensic interviews, including the use of open-ended, non-

leading, and “non-bias” questions. Although there was no specific testimony about

the exact nature of her interview with LCA, the juvenile court pointed out that there

was no indication that the social worker had deviated from her typical protocol and

training for the interview with LCA.

{¶11} The juvenile court noted father’s assertion that LCA had a motive to

fabricate the sexual abuse because he had recently disciplined her for going to a

friend’s home without permission. The child relayed to the social worker that father

4 OHIO FIRST DISTRICT COURT OF APPEALS

had dragged her out of the home by her hair and had beaten her with a garden hose.

As the juvenile court pointed out, the child’s statements about the physical nature of

the discipline were corroborated by statements made by mother and by an injury to

LCA’s lip.

{¶12} As to whether the child understood the need to tell the truth, the

juvenile court noted that both the social worker and the HCJFS caseworker testified

that they had advised the child of the importance of telling the truth. The court

noted that the child was 13 years old at the time of the interview, and that the child

answered the questions in an age-appropriate manner. The court also noted the

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2020 Ohio 5243, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-ca-children-ohioctapp-2020.