In re H.P.

2022 Ohio 778
CourtOhio Court of Appeals
DecidedMarch 16, 2022
Docket29973, 29975
StatusPublished
Cited by6 cases

This text of 2022 Ohio 778 (In re H.P.) 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.P., 2022 Ohio 778 (Ohio Ct. App. 2022).

Opinion

[Cite as In re H.P., 2022-Ohio-778.]

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

IN RE: H.P. C.A. Nos. 29973 29975

APPEAL FROM JUDGMENT ENTERED IN THE COURT OF COMMON PLEAS COUNTY OF SUMMIT, OHIO CASE No. DN 20-10-680

DECISION AND JOURNAL ENTRY

Dated: March 16, 2022

CARR, Presiding Judge.

{¶1} Appellants, A.S. (“Mother”) and T.P. (“Father”), appeal from a judgment of the

Summit County Court of Common Pleas, Juvenile Division, that adjudicated their minor child

dependent and placed the child in the temporary custody of Summit County Children Services

Board (“CSB”). This Court affirms.

I.

{¶2} Mother is the biological mother of H.P., born October 7, 2020. Father is the child’s

alleged father, but paternity was not established during the relevant proceedings in the trial court.

{¶3} On October 15, 2020, CSB filed a complaint, alleging that H.P. was an abused and

dependent child because, among other reasons, Mother had tested positive for fentanyl and

methamphetamine at the hospital shortly before H.P. was born. The complaint further alleged that

H.P. had remained in the neonatal intensive care unit (“NICU”) for several days to be observed for

symptoms of drug withdrawal; the infant exhibited mild symptoms of withdrawal; and the child 2

would be released to the home where Mother resided with Father and each parent had a history of

unresolved substance abuse problems.

{¶4} Following the adjudicatory hearing, the trial court found that CSB had failed to

prove its allegations of abuse, but it adjudicated H.P. a dependent child under R.C. 2151.04(C).

The child was later placed in the temporary custody of CSB. Mother and Father filed objections

to the magistrate’s adjudicatory decision, which were overruled by the trial court. The trial court

independently entered judgment adjudicating H.P. dependent and placing the child in the

temporary custody of CSB. Mother and Father appeal and each raise three assignments of error.

Because their assignments of error and supporting arguments are virtually identical, we will

address them jointly.

II.

APPELLANTS’ ASSIGNMENT OF ERROR I

THE TRIAL COURT COMMITTED REVERSIBLE ERROR AT THE ADJUDICATORY HEARING BY ADMITTING INTO EVIDENCE AND CONSIDERING A HOSPITAL SOCIAL WORKER’S TESTIMONY IN VIOLATION OF R.C. 2317.02(G)(1).

{¶5} The parents’ first assignment of error challenges the trial court’s admission and

consideration of the testimony of a hospital social worker that Mother admitted to her that she had

relapsed on fentanyl and snorted it “a handful of times” within the week and a half before H.P.

was born. The hospital social worker spoke to Mother on the day of H.P.’s birth because of

concerns that Mother may have used drugs while pregnant with H.P. After Mother admitted using

fentanyl while pregnant, the social worker informed Mother that she was a mandatory reporter and

would have to make a report to CSB. 3

{¶6} At the adjudicatory hearing and after the magistrate’s decision, the parents timely

objected to the social worker testifying about her communication with Mother, asserting that it

was privileged under R.C. 2317.02(G)(1), which provides:

A * * * person licensed under Chapter 4757. of the Revised Code as a * * * social worker [shall not testify] * * * concerning a confidential communication received from a client in that relation or the person’s advice to a client unless [an enumerated exception] applies.

{¶7} The parents have presented a lengthy argument under this assignment of error,

much of which focuses on whether the communication that Mother had with the social worker was

potentially privileged under R.C. 2317.02(G), the policy behind the privileges set forth in R.C.

2317.02, and the fact that Mother did not explicitly waive any privilege that she may have had.

This Court will not address those broader issues but will confine its review to whether the trial

court correctly ruled that the social worker’s testimony was admissible under an exception to the

privilege.

{¶8} The trial court concluded that the social worker’s communication with Mother fell

within the privilege exception set forth in R.C. 2317.02(G)(1)(a), which provides that a social

worker may testify about an otherwise privileged communication if:

[t]he communication or advice indicates clear and present danger to the client or other persons. For the purposes of this division, cases in which there are indications of present or past child abuse or neglect of the client constitute a clear and present danger.

(Emphasis added.)

{¶9} This Court will first address the parents’ argument that interprets the second

sentence of this exception to mean that “indications of present or past child abuse” must involve

only child abuse of the client and not an “other person.” This argument lacks merit for numerous

reasons. 4

{¶10} Evid.R. 501 provides that issues of privilege are governed by statute and by

principles of common law as interpreted by Ohio courts. “The traditional policy of the law is to

require the disclosure of all information by those in possession of it, in order that the truth may be

discovered and justice prevail.” In re Briggs, 9th Dist. Summit No. 18117, 1997 WL 416331, *6,

quoting Belichick v. Belichick, 37 Ohio App.2d 95, 96-97 (7th Dist.1974). Because privileges

against disclosure are exceptions to this general rule, “the tendency of the courts is to construe

such privileges strictly and to narrow their scope since they obstruct the discovery of the truth.”

Id. Therefore, this Court must construe the plain language of this exception in a manner that

favors, rather than restricts, disclosure of the communication.

{¶11} By the clear language of R.C. 2317.02(G)(1)(a), the sole requirement of this

exception is stated in the first sentence: “[t]he communication or advice indicates clear and present

danger to the client or other persons.” The term “clear and present danger” is commonly

understood to refer to a danger that is “immediate” and “severe.” Black’s Law Dictionary 269 (8th

Ed.2004) (defining the term as it is used in First Amendment law). For example, under this

common meaning, if a client told a social worker that she planned to kill a specific person, that

communication would indicate a “clear and present danger” to that “other person.”

{¶12} The second sentence of R.C. 2317.02(G)(1)(a) is not set forth as a definition of the

term “clear and present danger,” nor does it limit the common meaning of that term. Instead, the

second sentence broadens the scope of what might otherwise be understood to be a “clear and

present danger” by giving two examples of dangers that are not necessarily immediate and/or

severe: those that indicate “present or past child abuse” and those that indicate “neglect of the

client.” 5

{¶13} Indications of past child abuse would not otherwise constitute an immediate danger

to the client or an “other person,” but the second sentence of R.C. 2317.02(G)(1)(a) explicitly

states that past child abuse falls within the meaning of “clear and present danger” as the term is

used in this exception. Another appellate district has interpreted this exception to encompass

communications that indicate present or past child abuse of a person other than the client. See,

e.g., In re Hauenstein, 3d Dist. Hancock Nos. 5-03-38 and 5-03-39, 2004-Ohio-2915, ¶ 8-13; State

v.

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2022 Ohio 778, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-hp-ohioctapp-2022.