In re J.L.

2026 Ohio 576
CourtOhio Court of Appeals
DecidedFebruary 19, 2026
Docket2025 CA 00136
StatusPublished

This text of 2026 Ohio 576 (In re J.L.) 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 J.L., 2026 Ohio 576 (Ohio Ct. App. 2026).

Opinion

[Cite as In re J.L., 2026-Ohio-576.]

COURT OF APPEALS STARK COUNTY, OHIO FIFTH APPELLATE DISTRICT

IN THE MATTER OF: J.L. Case No. 2025 CA 00136

Opinion And Judgment Entry

Appeal from the Court of Common Pleas, Family Court Division,Case No.2024JCV01163

Judgment: Affirmed

Date of Judgment Entry: February 19, 2026

BEFORE: Andrew J. King; Kevin W, Popham; David M. Gormley, Appellate Judges

APPEARANCES: RICHARD D. HIXSON, for Defendant-Appellant; JAMES B. PHILLIPS, for Plaintiff-Appellee.

King, P.J.

{¶ 1} Appellant B.C. (Mother) appeals the September 10, 2025 judgment of the

Stark County Court of Common Pleas Family Court which terminated her parental rights

and granted permanent custody of minor child J.L to the Stark County Department of Job

and Family Services (SCJFS). We affirm the trial court.

Facts and Procedural History

{¶ 2} Mother gave birth to J.L. on September 29, 2024 while incarcerated. On

October 1, 2024, SCJFS filed a permanent custody complaint alleging dependency of J.L.

and requesting J.L. be placed into the emergency custody of SCJFS. The following day,

the trial court granted SCJFS temporary custody of the child. J.L. was placed with the

same foster family that had adopted her three-year-old half-sibling. {¶ 3} The trial court reviewed the case every six months and found SCJFS had

made reasonable efforts to prevent continued removal.

{¶ 4} On May 29, 2025, SCJFS filed a motion for permanent custody.

{¶ 5} On September 9, 2025, the trial court heard testimony on the motion for

permanent custody. At the time of the hearing, Mother was incarcerated for child

endangering involving J.L's half-sister, and appeared via video.

{¶ 6} Because Mother was incarcerated, no case plan was developed for her. As

of the date of the hearing, Mother's earliest release date was November, 2026. Mother

testified that even if she were released at that time, her release would be into a halfway

house. Mother further confirmed she had not seen J.L. since she was born, and could not

articulate what was in J.L.'s best interest. She did state she would like J.L. and her father

to reunify, however, Father is also incarcerated and further, had never met J.L.

{¶ 7} SCJFS caseworker Thomas testified J.L. had no bond with Mother as her

foster parents are the only parents she has known. Thomas indicated that due to Mother's

previous child endangering charges she would have an extensive case plan to complete

and based on her anticipated release date, would not have time to complete that plan.

Thomas further advised the trial court that J.L.'s foster parents wished to adopt her if the

trial court granted SCJFS permanent custody.

{¶ 8} After taking the matter under advisement, on September 10, 2025 the trial

court granted the motion for permanent custody to SCJFS and terminated Mother's

parental rights. The trial court found Mother had abandoned J.L. and had previously been

convicted of child endangering pursuant to R.C. 2919.22(A) for abusing J.L.'s sibling. {¶ 9} Mother appealed and the matter is now before this court for consideration.

She raises one assignment of error as follows:

I

{¶ 10} "THE TRIAL COURT ERRED WHEN IT FOUND PERMANENT CUSTODY

WAS IN THE BEST INTERESTS OF THE MINOR CHILDREN." (sic)

{¶ 11} In her sole assignment of error, Mother argues the trial court erred in

concluding permanent custody was in J.L.'s best interest. We disagree.

Applicable Law

{¶ 12} As an initial matter, Mother asserts that an abuse of discretion standard

applies when reviewing whether clear and convincing evidence supports a trial court's

permanent custody judgment. However, in In re Z.C., 2023-Ohio-4703, ¶ 18, the Supreme

Court of Ohio stated:

[T]he proper appellate standards of review to apply in cases involving

a juvenile court's decision under R.C. 2151.414 to award permanent

custody of a child and to terminate parental rights are the sufficiency-

of-the-evidence and/or manifest-weight-of-the-evidence standards,

as appropriate depending on the nature of the arguments that are

presented by the parties.

Sufficiency of the Evidence

{¶ 13} Whether the evidence is legally sufficient to sustain a verdict is a question

of law. In re: Z.C., 173 Ohio St. 3d 359, 2023-Ohio-4703, ¶13, 230 N.E.3d 1123. "When applying a sufficiency-of-the-evidence standard, a court of appeals should affirm a trial

court when 'the evidence is legally sufficient to support the jury verdict as a matter of

law.' " Bryan-Wollman v. Domonko, 115 Ohio St. 3d 291, 2007-Ohio-4918, 874 N.E.2d

1198, ¶ 3, quoting Thompkins at 386, 678 N.E.2d 541, quoting Black's at 1433. Id.

{¶ 14} Clear and convincing evidence is that evidence "which will provide in the

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

Cross v. Ledford, 161 Ohio St. 469, 120 N.E.2d 118 (1954), paragraph three of the

syllabus. See In re Adoption of Holcomb, 18 Ohio St. 3d 361(1985). "Where the degree

of proof required to sustain an issue must be clear and convincing, a reviewing court will

examine the record to determine whether the trier of facts had sufficient evidence before

it to satisfy the requisite degree of proof." Cross at 477. Sufficiency of the evidence "is a

test of adequacy. Whether the evidence is legally sufficient to sustain a verdict [decision]

is a question of law." State v. Thompkins, 78 Ohio St. 3d 380, 386 (1997).

Manifest Weight

{¶ 15} On review for manifest weight, the standard in a civil case is identical to the

standard in a criminal case: a reviewing court is to examine the entire record, weigh the

evidence and all reasonable inferences, consider the credibility of witnesses and

determine "whether in resolving conflicts in the evidence, the jury [or finder of fact] clearly

lost its way and created such a manifest miscarriage of justice that the conviction

[decision] must be reversed and a new trial ordered." State v. Martin, 20 Ohio App. 3d

172, 175 (1st Dist.1983). In Thompkins, supra, at 387, quoting Black's Law Dictionary

1594 (6th Ed.1990), the Supreme Court of Ohio explained the following: Weight of the evidence concerns "the inclination of the greater

amount of credible evidence, offered in a trial, to support one side of

the issue rather than the other. It indicates clearly to the jury that the

party having the burden of proof will be entitled to their verdict, if, on

weighing the evidence in their minds, they shall find the greater

amount of credible evidence sustains the issue which is to be

established before them. Weight is not a question of mathematics,

but depends on its effect in inducing belief." [Emphasis sic.]

{¶ 16} In weighing the evidence, however, we are always mindful of the

presumption in favor of the trial court's factual findings. Eastley v. Volkman, 2012-Ohio-

2179. Additionally, "'Judgments supported by some competent, credible evidence going

to all the essential elements of the case will not be reversed by a reviewing court as being

against the manifest weight of the evidence.'" Seasons Coal Co., 10 Ohio St. 3d 77, 80,

(1984), quoting C.E. Morris Co. v. Foley Construction Co., 54 Ohio St. 2d 279, 280-281

(1978).

Permanent Custody

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Related

State v. Martin
485 N.E.2d 717 (Ohio Court of Appeals, 1983)
C. E. Morris Co. v. Foley Construction Co.
376 N.E.2d 578 (Ohio Supreme Court, 1978)
Seasons Coal Co. v. City of Cleveland
461 N.E.2d 1273 (Ohio Supreme Court, 1984)
In re Adoption of Holcomb
481 N.E.2d 613 (Ohio Supreme Court, 1985)
State v. Thompkins
678 N.E.2d 541 (Ohio Supreme Court, 1997)
Bryan-Wollman v. Domonko
874 N.E.2d 1198 (Ohio Supreme Court, 2007)
In re Z.C.
2023 Ohio 4703 (Ohio Supreme Court, 2023)
In re D.B.
2024 Ohio 1872 (Ohio Court of Appeals, 2024)

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Bluebook (online)
2026 Ohio 576, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-jl-ohioctapp-2026.