In re C.K.

2022 Ohio 3121
CourtOhio Court of Appeals
DecidedSeptember 7, 2022
Docket30183
StatusPublished

This text of 2022 Ohio 3121 (In re C.K.) 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.K., 2022 Ohio 3121 (Ohio Ct. App. 2022).

Opinion

[Cite as In re C.K., 2022-Ohio-3121.]

STATE OF OHIO ) IN THE COURT OF APPEALS )ss: NINTH JUDICIAL DISTRICT COUNTY OF SUMMIT )

IN RE: C.K. C.A. No. 30183 A.W. D.V. K.E. APPEAL FROM JUDGMENT ENTERED IN THE COURT OF COMMON PLEAS COUNTY OF SUMMIT, OHIO CASE Nos. DN 21 04 0319 DN 21 04 0320 DN 21 04 0321 DN 21 04 0322

DECISION AND JOURNAL ENTRY

Dated: September 7, 2022

HENSAL, Presiding Judge.

{¶1} Appellant, C.E. (“Mother”), appeals from a judgment of the Summit County Court

of Common Pleas, Juvenile Division, that adjudicated one of her minor children abused and

dependent and her other three children dependent. This Court reverses and remands.

I.

{¶2} Mother is the biological mother of C.K., born April 4, 2008; A.W., born August 9,

2016; D.V., born January 6, 2019; and K.E., born August 3, 2020. The fathers of the children did

not appeal from the trial court’s judgment.

{¶3} On April 26, 2021, CSB filed complaints, alleging that all four children were

neglected and dependent and that A.W. was abused, neglected, and dependent. The allegations

were based primarily on an incident from two days earlier, during which Mother had allegedly

disciplined A.W. with a belt after the child had started her doll’s hair on fire. The next day, while 2

A.W. was at the home of her grandfather (“Grandfather”), Grandfather contacted the police, who

observed bruising on A.W.’s back, arms, and legs. Because the police were concerned about the

safety of the other children, they invoked Rule 6 of the Ohio Rules of Juvenile Procedure to take

all four children into custody.

{¶4} The matter proceeded to an adjudicatory hearing before a magistrate. The evidence

focused almost exclusively on Mother’s act of discipling A.W. with a belt and trial counsel’s

arguments about whether that corporal punishment was so excessive that it constituted abuse under

Revised Code Section 2151.031. The evidence about the incident did not include any testimony

from Mother or A.W., and Grandfather did not testify about what Mother apparently told him

about the incident.

{¶5} Following the hearing, the magistrate decided that A.W. was an abused child and

that all four children were dependent under Section 2151.04(C) because of Mother’s abuse of A.W.

The trial court adopted the adjudicatory decision the same day, pending the filing of timely, written

objections. The trial court later adopted the magistrate’s dispositional decisions as to each child.

Mother did not raise objections to the dispositional orders, nor has she challenged them on appeal.

{¶6} Mother filed timely written objections to the magistrate’s adjudicatory decision,

which she supplemented after the transcript of the adjudicatory hearing was filed. She asserted

that the adjudication of A.W. as an abused child was not supported by the evidence presented at

the hearing. Because the dependency adjudications of all four children were based solely on the

finding that A.W. was abused under Section 2151.031, Mother asserted that her objections to the

magistrate’s decision should be sustained, and the complaints as to all four children should be

dismissed. 3

{¶7} The trial court overruled Mother’s objections and adjudicated A.W. an abused

child under Sections 2151.031(B), (C), and (D) and adjudicated all four children dependent under

Section 2151.04(C) based on its finding that Mother abused A.W. Mother appeals and raises two

assignments of error.

II.

ASSIGNMENT OF ERROR I

THE TRIAL COURT’S DECISION FINDING THAT A.W. WAS ABUSED WAS NOT SUPPORTED BY CLEAR AND CONVINCING EVIDENCE.

{¶8} Mother’s first assignment of error is that the trial court’s adjudication of A.W. as

an abused child was not supported by the evidence presented at the adjudicatory hearing. The trial

court found that A.W. was an abused child under Revised Code Sections 2151.031(B), (C), and

(D). In relevant part, those provisions define an abused child as one who:

(B) Is endangered as defined in section 2919.22 of the Revised Code * * *;

(C) Exhibits evidence of any physical * * * injury * * *. Except as provided in division (D) of this section, a child exhibiting evidence of corporal punishment or other physical disciplinary measure by a parent * * * is not an abused child under this division if the measure is not prohibited under section 2919.22 of the Revised Code.

(D) Because of the acts of his parents, * * * suffers physical * * * injury that harms or threatens to harm the child’s health or welfare.

Of relevance here, Section 2919.22(B)(3) prohibits a person from: [a]dminister[ing] corporal

punishment or other physical disciplinary measure or physically restrain[ing] the child in a cruel

manner or for a prolonged period, which punishment, discipline, or restraint is excessive under the

circumstances and creates a substantial risk of serious physical harm to the child[.]”

{¶9} The trial court was authorized to adjudicate A.W. an abused child only if it found

that clear and convincing evidence demonstrated that Mother abused A.W. See R.C.

2151.35(A)(1) and Juv.R. 29(E)(4). Clear and convincing evidence is that which will “produce in 4

the mind of the trier of facts a firm belief or conviction as to the facts sought to be established.”

In re Adoption of Holcomb, 18 Ohio St.3d 361, 368 (1985), quoting Cross v. Ledford, 161 Ohio

St. 469 (1954), paragraph three of the syllabus. Where the proof required must be clear and

convincing, this Court will examine the evidence presented at the adjudicatory hearing to

determine whether the trial court had sufficient evidence before it to satisfy the requisite degree of

proof. In re J.A., 9th Dist. Summit No. 29462, 2020-Ohio-4677, ¶ 25.

{¶10} The sole reason for the trial court’s abuse adjudication was the single incident

during which Mother disciplined A.W. with a belt because the child had started her doll’s hair on

fire in her bedroom. Mother asserted in the trial court and again on appeal, however, that CSB

failed to present clear and convincing evidence that this single incident of corporal punishment

constituted abuse of A.W. This Court agrees.

{¶11} We begin by emphasizing that a parent’s use of corporal punishment to discipline

her minor child does not necessarily constitute abuse. See In re K.B., 9th Dist. Summit No. 21365,

2003-Ohio-3784, ¶ 14. CSB has asserted on appeal that a parent’s use of a belt to discipline a

child, in and of itself, constitutes abuse. That argument is not supported by Ohio law. In fact, this

Court has stressed that the appearance of a slight injury that resulted from a parent’s use of corporal

punishment does not necessarily constitute abuse. Id. at ¶ 15. To determine whether Mother’s

punishment of A.W. exceeded the bounds of reasonableness and constituted abuse, the trial court

was required to examine the totality of the circumstances surrounding the incident. Id. “Specific

factors to be considered * * * include the circumstances giving rise to the harm to the child, the

past history of the child, the nature and manner of the discipline administered to the child and the

measure of discipline.” (Internal citation and quotations omitted.) Id. 5

Extent of Injury

{¶12} In reviewing the totality of circumstances surrounding an alleged incident of abuse,

courts often focus on the extent of the injury. In In re K.B., 2003-Ohio-3784, ¶ 24, an appeal from

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2022 Ohio 3121, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-ck-ohioctapp-2022.