In re H.-A.C. M.

2022 Ohio 2912
CourtOhio Court of Appeals
DecidedAugust 22, 2022
Docket22CA0006-M
StatusPublished

This text of 2022 Ohio 2912 (In re H.-A.C. M.) 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 H.-A.C. M., 2022 Ohio 2912 (Ohio Ct. App. 2022).

Opinion

[Cite as In re H.-A.C. M., 2022-Ohio-2912.]

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

IN RE: H.-A.C. M. C.A. No. 22CA0006-M

APPEAL FROM JUDGMENT ENTERED IN THE COURT OF COMMON PLEAS COUNTY OF MEDINA, OHIO CASE No. 2021 09 DE 0043

DECISION AND JOURNAL ENTRY

Dated: August 22, 2022

CALLAHAN, Judge.

{¶1} Appellant Mother appeals the judgment of the Medina County Court of Common

Pleas, Juvenile Division, that granted legal custody of her child to the child’s maternal

grandmother (“Grandmother”). This Court affirms.

I.

{¶2} Mother and Father are the biological parents of H.-A.C. M., born January 18, 2019.

Mother was the child’s sole legal custodian. Father had not had a significant presence in the child’s

life and was serving a prison sentence in California at all times during the juvenile court

proceedings below. At some time prior to the initiation of the juvenile dependency case, Mother

was charged with felonies in California and Georgia. As Mother was being held in a detention

center in California on various charges, including murder, Grandmother was caring for H.-A.C.

M. in Ohio, and was able to obtain a limited guardianship of the child. Because of jurisdictional

issues, she was unable to assume the child’s permanent guardianship. As the child needed 2

someone who was available and authorized to make medical and educational decisions on his

behalf, and the limited guardianship was about to expire, Medina County Job and Family Services

(“JFS” or “the agency”) filed a complaint in which it alleged that H.-A.C. M. was a dependent

child. At the same time, the agency moved for a predispositional order of temporary custody. JFS

did not remove the child but allowed him to remain in Grandmother’s home.

{¶3} A week later, the magistrate issued a decision granting predispositional custody to

JFS. The decision indicated that neither Mother nor Father was present but that they had been

duly notified of the hearing. The juvenile court subsequently adopted the magistrate’s decision

and served that journal entry on the attorney the court had recently appointed to represent Mother.

{¶4} JFS filed a proposed case plan. Grandmother, as the child’s caregiver, was required

to continue to provide for the child’s basic needs and ensure that he was engaged in Early

Intervention services. Both Mother and Father were required to contact the JFS caseworker upon

their respective releases from incarceration to collaborate regarding substantive case plan

objectives and visitation schedules.

{¶5} A week prior to the adjudicatory hearing, JFS filed an amended complaint,

requesting legal custody of the child to Grandmother, or alternatively, temporary custody to the

agency. JFS requested that the clerk of court serve Mother and Father with the amended complaint

by certified mail where each was incarcerated in California.

{¶6} According to the juvenile court’s journal entry, Mother did not attend the

adjudicatory hearing, but she was represented by counsel who informed the judge that Mother

agreed to the child’s adjudication as a dependent child. As Father was neither present nor

represented, the court held an evidentiary hearing. Citing Mother’s stipulation to dependency,

both parents’ incarcerations, Mother’s multiple pending felony charges in two states, and the 3

termination of the child’s limited guardianship, the juvenile court adjudicated H.-A.C. M.

dependent.

{¶7} The juvenile court subsequently held a dispositional hearing. The court’s

dispositional journal entry notes that Mother’s attorney appeared virtually for the hearing, while

Mother and Father were not present for disposition “although [both were] duly notified[.]”

{¶8} After the conclusion of the dispositional hearing, the juvenile court granted legal

custody of the child to Grandmother. The court enumerated the efforts made by JFS to remedy

the circumstances that led to the child’s removal but found that the “complex nature of the

circumstances precluded remedy prior to hearing.” Specifically, the court found that the “[c]hild

cannot be reunified at this time due to Mother’s and Father’s current incarceration. Mother and

Father are expected to be incarcerated for the foreseeable future in the State of California.”

{¶9} Mother wrote a letter to the juvenile court, requesting appointed counsel for

purposes of appealing the juvenile court’s award of legal custody to Grandmother. The juvenile

court appointed appellate counsel who filed a timely notice of appeal from the judgment on

Mother’s behalf. Mother raises two assignments of error for consideration.

II.

ASSIGNMENT OF ERROR I

THE TRIAL COURT ABUSED ITS DISCRETION WHEN IT VIOLATED MOTHER’S FUNDAMENTAL RIGHT TO DUE PROCESS AND GRANTED LEGAL CUSTODY TO MATERNAL GRANDMOTHER WHEN MOTHER WAS NOT PRESENT AT THE PROCEEDINGS.

{¶10} Mother argues that she was deprived of due process when the juvenile court

conducted the legal custody hearing in her absence. This Court disagrees.

{¶11} In support of her argument, Mother cites to this Court’s determination in In re

Frasher, 9th Dist. Summit No. 18100, 1997 WL 537666, *2 (Aug. 20, 1997), that an absent 4

parent’s due process rights in a custodial dispositional hearing are not violated as long as the parent

is represented by counsel at the hearing, the trial court makes a full record of the hearing, and “any

testimony that [the absent parent] may wish to present could be presented by way of deposition.”

Mother does not dispute that she had appointed counsel who was present and represented her

interests during the legal custody hearing. She also does not dispute that the juvenile court made

a full record of that hearing. That record is before this Court for consideration.

{¶12} Mother argues solely that she was deprived of due process because her absence

prevented her from testifying or otherwise presenting evidence on her behalf. Specifically, Mother

argues that she might have appeared for the hearing via a Zoom connection, as others were

permitted to do so due to Covid-19 pandemic protocols. Mother’s argument is not persuasive.

{¶13} The record contains clear indications that Mother had contact with her attorney

throughout the case. She does not allege that her attorney failed to provide her with the Zoom link

so that she might have attempted to coordinate with officials in California where she was

incarcerated to join the hearing remotely. Mother does not argue that she would have had access

to technology while incarcerated so that she could have attended the hearing remotely. Finally,

she does not assert that she had expressed any interest to her attorney or the court either that she

attend remotely or be deposed for purposes of providing her testimony for consideration during

the hearing.

{¶14} Akin to the situation in In re Frasher, Mother was represented by counsel who

cross-examined the agency’s witness and advocated Mother’s position to the court, the court made

a full record of the proceedings, there were no assurances that Mother would have had access to

the necessary technology to appear remotely for the hearing from the justice center in which she

was incarcerated, and Mother “did not offer to present any testimony by way of deposition.” See 5

id. at *2. Accordingly, Mother’s absence from the legal custody hearing did not result in a

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Bluebook (online)
2022 Ohio 2912, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-h-ac-m-ohioctapp-2022.