In re J.P.

2025 Ohio 3293
Procedural entryThis page is a short order in In re J.P.. Read the opinion of the Court — 2023 Ohio 4816
Ohio Court of Appeals·Decided September 12, 2025·No. 30437·Published

Opinion

[Cite as In re J.P., 2025-Ohio-3293.]

IN THE COURT OF APPEALS OF OHIO SECOND APPELLATE DISTRICT MONTGOMERY COUNTY

IN RE: J.P. : : C.A. No. 30437 : : Trial Court Case No. C-2022-003534- : 0N,0Q : : (Appeal from Common Pleas Court- : Juvenile Division) : : FINAL JUDGMENT ENTRY & OPINION ...........

Pursuant to the opinion of this court rendered on September 12, 2025, the judgment

of the trial court is affirmed.

Costs to be paid as stated in App.R. 24.

Pursuant to Ohio App.R. 30(A), the clerk of the court of appeals shall immediately

serve notice of this judgment upon all parties and make a note in the docket of the service.

Additionally, pursuant to App.R. 27, the clerk of the court of appeals shall send a certified

copy of this judgment, which constitutes a mandate, to the clerk of the trial court and note

the service on the appellate docket.

For the court,

MICHAEL L. TUCKER, JUDGE

EPLEY, P.J., and LEWIS, J., concur. -2- OPINION MONTGOMERY C.A. No. 30437

ROBERT ALAN BRENNER, Attorney for Appellant, Mother SARAH H. CHANEY, Attorney for Appellee, Montgomery County Children Servies GARY C. SCHAENGOLD, Attorney for Appellee, Father

TUCKER, J.

{¶ 1} Appellant (“Mother”) appeals from the decision of the Montgomery County Court

of Common Pleas, Juvenile Division, granting legal custody of her daughter J.P. to Appellee

Father. For the reasons outlined below, we affirm.

I. Factual and Procedural History

{¶ 2} Mother and Father are the biological parents of J.P., a minor born in January

2020. On August 19, 2022, the Montgomery County Department of Job and Family Services,

Children Services Division (“MCCS”) filed a complaint alleging that J.P. was a dependent

child, as defined under R.C. 2151.04(B) and (C). The complaint alleged that Mother was

using methamphetamine and leaving needles within reach of J.P. The complaint further

alleged that Mother and the child did not have housing.

{¶ 3} J.P. was adjudicated dependent on November 7, 2022, and temporary custody

was granted to the child’s maternal grandmother. Mother was granted supervised visitation

and Father was granted unsupervised visitation. In October of 2023, temporary custody of

the child was transferred to MCCS. Both parents were granted visitation. MCCS created

case plans for both parents.

{¶ 4} In early 2024, both parents filed motions seeking legal custody of the child. On

July 23, 2024, MCCS filed a motion seeking the grant legal custody of J.P. to Father. In

support of the motion, MCCS noted that Mother had a drug relapse in February of 2024 and -3- had failed to maintain stable employment. MCCS noted that Father had maintained stable

housing and employment throughout the duration of the case. The Guardian Ad Litem

(“GAL”) filed a report in September of 2024. The GAL’s report noted Mother’s drug relapse.

The report also noted that Mother had refused to agree to shared parenting. The GAL

recommended that Father be awarded legal custody.

{¶ 5} The parties and their attorneys appeared before the assigned juvenile court

magistrate on September 19, 2024, for a dispositional hearing on MCCS’s motion regarding

the legal custody of J.P. The magistrate and parties discussed a proposed parenting time

schedule. The transcript of the hearing reveals that at the beginning of the hearing, Mother

was confused regarding the parenting time she would have under the agreement. It appears

she believed the agreement provided she would have a week with visitation followed by a

week without. The magistrate clarified that Mother would have visitation every week.

Mother’s visitation was to take place from Friday afternoon until Monday morning every other

week, and on the alternate week she would have visitation from Thursday after school until

Friday evening.

{¶ 6} The magistrate explained that Mother would retain residual rights and what

those rights included. Mother asked, “[t]hen why can’t we do shared parenting?” The

magistrate noted that such a plan had not been requested and was not properly before the

court at that time. The magistrate and the parties further discussed parenting time after

which Mother reiterated that she was frustrated and did not understand “why shared

parenting’s not on the table for me.” The magistrate asked Mother whether she agreed to

awarding legal custody to Father or whether the court needed to set a hearing on the matter.

Mother responded, “I mean, I don’t know. I mean, no, I’m not in agreement with him having

legal custody.” Mother stated, “I just want [J.P.] to have both of us[,]” and expressed concern -4- that Father, as legal custodian, would be able to deny her parenting time. The magistrate

informed her that the parenting time schedule they discussed was the minimum amount of

visitation Mother would be awarded. Mother did not voice any other objection after that.

{¶ 7} The magistrate proceeded to take testimony from the ongoing caseworker

assigned to J.P. regarding the best interest of the child. Both Mother and Father were given

the opportunity to conduct cross-examination. Following the conclusion of testimony, the

magistrate stated that legal custody would be awarded to Father. The magistrate discussed

child support with the parties and determined that a minimum support order was appropriate.

The magistrate concluded by asking whether the parties had more to discuss. When both

parties responded in the negative, the magistrate adjourned court.

{¶ 8} The magistrate issued a decision which stated that the parties had “knowingly,

intelligently, and voluntarily entered into an . . . agreement in which legal custody would be

granted to [Father].” The decision granted legal custody to Father upon a finding that doing

so was in the best interest of the child. Mother filed objections in which she claimed she had

not agreed to such a disposition. She further claimed that trial counsel was ineffective.

{¶ 9} The juvenile court overruled Mother’s objections and adopted and affirmed the

magistrate’s decision.

{¶ 10} Mother’s timely appeal followed.

II. Legal Custody

{¶ 11} Mother’s assignment of error states:

THE JUVENILE COURT ABUSED ITS DISCRETION IN GRANTING LEGAL

CUSTODY TO FATHER BASED ON AN AGREEMENT OF THE PARTIES. -5- {¶ 12} Mother claims the record “does not support a finding that [she] voluntarily

relinquished her rights to custody[.]” She contends the juvenile court erred by awarding legal

custody to Father.1

{¶ 13} R.C. Chapter 2151 grants a juvenile court exclusive original jurisdiction

concerning a child alleged to be abused, neglected, or dependent. In re A.D., 2023-Ohio-

2442, ¶ 59 (3d Dist.). Once a child has been adjudicated dependent, R.C. 2151.353(A)

provides the juvenile court with several dispositional alternatives for the child. Relevant to

this case, R.C. 2151.353(A)(3) authorizes the juvenile court to award legal custody of a

dependent child “to either parent or to any other person who, prior to the dispositional

hearing, files a motion requesting legal custody of the child.”

{¶ 14} “Legal custody” constitutes “a legal status that vests in the custodian the right

to have physical care and control of the child and to determine where and with whom the

child shall live, and the right and duty to protect, train, and discipline the child and to provide

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