In re R.H.

CourtOhio Court of Appeals
DecidedJune 10, 2026
Docket26 HA 0003
StatusPublished

This text of In re R.H. (In re R.H.) 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 R.H., (Ohio Ct. App. 2026).

Opinion

[Cite as In re R.H., 2026-Ohio-2177.]

IN THE COURT OF APPEALS OF OHIO SEVENTH APPELLATE DISTRICT HARRISON COUNTY

IN RE: R.H.

OPINION AND JUDGMENT ENTRY Case No. 26 HA 0003

Civil Appeal from the Court of Common Pleas, Juvenile Division, of Harrison County, Ohio Case No. 20253032

BEFORE: Mark A. Hanni, Cheryl L. Waite, Carol Ann Robb, Judges.

JUDGMENT: Affirmed.

Atty. Christopher P. Lacich, Roth, Blair, for Appellant and

Atty. Lauren E. Knight, Harrison County Prosecutor, and Atty. Jack L. Felgenhauer, Assistant Prosecuting Attorney, for Appellee.

Dated: June 10, 2026 –2–

HANNI, J.

{¶1} Appellant, mother, appeals from a Harrison County Common Pleas Court, Juvenile Division, decision terminating her parental rights as to her child R.H. and granting permanent custody of the child to Appellee, the Harrison County Department of Job and Family Services (the agency). Mother argues the trial court abused its discretion in terminating her parental rights and its decision was against the manifest weight of the evidence. Because the trial court’s judgment was not against the manifest weight of the evidence, the court’s judgment is affirmed. {¶2} Mother and father were married in June 2023. Father is a convicted sex offender. Mother gave birth to R.H. (the child) on October 20, 2025. {¶3} On October 23, 2025, the agency filed a complaint of dependency and motion for ex-parte emergency shelter care. The motion alleged that hospital staff contacted the agency when mother’s sister was the one caring for the child after his birth. Hospital staff indicated that mother would not get out of bed for 19 hours after giving birth and mother and father had to be reminded to feed the child. Further investigation revealed that mother has had three children permanently removed from her custody in Wayne County, Ohio. Father is not the biological father of these three children. Additionally, father was convicted in 1997 for rape, gross sexual imposition, and unlawful sexual conduct with a minor. Father was again convicted in 2003 for gross sexual imposition with a victim under age 13. In March 2021, one of mother’s children disclosed sexual abuse by father. This led to mother’s rights being terminated as to her three children in March 2023. While her appeal was pending, mother married father in June 2023. Mother indicated during the current investigation that she believed the child would be safe because father would not victimize his own child. {¶4} The trial court granted the motion for emergency shelter care. It then set the matter for an adjudicatory hearing. {¶5} On November 5, 2025, the agency filed a motion for disposition of permanent custody. It requested that in the event the court adjudicated the child dependent, the court then order a disposition of permanent custody to the agency. The motion asserted the reason for the permanent removal of mother’s other three children

Case No. 26 HA 0003 –3–

was that mother failed to protect them from father, who was then and still is, a registered sex offender due to prior assault/abuse convictions involving children. {¶6} The court next appointed a guardian ad litem (GAL) for the child. {¶7} Mother filed a motion for visitation with the child on December 15, 2025. {¶8} The court held an adjudication hearing on January 12, 2026. It adjudicated the child dependent and set the matter for a disposition hearing. The court also overruled mother’s motion for visitation finding that the agency did not have to provide reasonable efforts at reunification given the previous permanent removal of mother’s other three children. {¶9} The court held the disposition hearing on March 4, 2026. It heard testimony from the GAL, the social services worker, and mother. Father appeared at the hearing but did not testify. {¶10} The trial court issued its judgment the next day granting permanent custody to the agency and terminating mother’s and father’s parental rights. The court found that the agency used reasonable efforts to reunify this family; however, the child cannot be reunited with either mother or father within a reasonable amount of time nor are they suitable to parent the child. The court found it in was in the child’s best interest to grant his permanent custody to the agency. {¶11} Mother filed a timely notice of appeal on March 30, 2026. Father did not file an appeal. {¶12} Mother now raises a single assignment of error, which states:

THE JUVENILE COURT COMMITTED REVERSIBLE ERROR IN GRANTING HCDJFS’ MOTION FOR PERMANENT CUSTODY OF THE MINOR CHILD R.H. FOR THE SAME WAS NOT THE LAST RESORT, NO REASONABLE EFFORT WAS MADE FOR REUNIFICATION, AND THUS THE SAME WAS AGAINST THE MANIFEST WEIGHT OF THE EVIDENCE AND AN ABUSE OF DISCRETION.

{¶13} A parent’s right to raise his or her children is an essential and basic civil right. In re Murray, 52 Ohio St.3d 155, 157 (1990), citing Stanley v. Illinois, 405 U.S. 645, 651 (1972). “Permanent termination of parental rights has been described as ‘the family law equivalent of the death penalty in a criminal case.' In re Smith (1991), 77 Ohio App.3d

Case No. 26 HA 0003 –4–

1, 16, 601 N.E.2d 45, 54.” In re Hayes, 79 Ohio St.3d 46, 48 (1997). However, this right is not absolute. In re Sims, 2002-Ohio-3458, ¶ 23 (7th Dist.). In order to protect a child's welfare, the state may terminate parents’ rights as a last resort. Id. {¶14} Initially, we note the agency first raises an issue with the fact that mother never requested findings of fact and conclusions of law. In spite of this, the trial court issued a judgment that included findings of fact and conclusions of law. The agency now asserts that because mother never requested findings of fact and conclusions of law, she cannot now assert on appeal any error as to these findings of fact and conclusions of law. {¶15} The agency’s argument on this point is disingenuous. The trial court held the disposition hearing on March 4, 2026. The court issued its judgment entry containing findings of fact and conclusions of law the very next day (March 5, 2026). Thus, there was no opportunity and no reason for mother to request the same. {¶16} Mother first argues the evidence did not support the trial court’s finding that the agency “used reasonable efforts to reunify this family.” She asserts she was never given a case plan and no efforts were made to reunify the child with her. She further argues the trial court did not rule on her motion for visitation while this matter was pending. {¶17} On December 15, 2025, mother filed a motion to establish visitation with the child. The trial court held the adjudicatory hearing on January 12, 2026. On January 13, 2026, the court issued its judgment entry adjudicating the child dependent. In this judgment entry, the court specifically “Denies [mother’s] Motion to Establish Visitation as [the agency] does not have to provide reasonable efforts toward [mother] due to the previous permanent removal of three of her children.” Thus, contrary to mother’s assertion, the court did rule on her motion for visitation. {¶18} Next, we note the trial court erroneously stated in its March 5, 2026 judgment entry that the agency “used reasonable efforts to reunify this family[.]” The agency was not required to make reasonable efforts at reunification at this stage in the proceedings. {¶19} Pursuant to R.C. 2151.419(A):

(A)(1) Except as provided in division (A)(2) of this section, at any hearing . . . at which the court removes a child from the child's home or continues the removal of a child from the child's home, the court shall determine

Case No. 26 HA 0003 –5–

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Related

Stanley v. Illinois
405 U.S. 645 (Supreme Court, 1972)
Eastley v. Volkman
2012 Ohio 2179 (Ohio Supreme Court, 2012)
In the Matter of A.C., Unpublished Decision (10-18-2004)
2004 Ohio 5531 (Ohio Court of Appeals, 2004)
In Re Smith
601 N.E.2d 45 (Ohio Court of Appeals, 1991)
Seasons Coal Co. v. City of Cleveland
461 N.E.2d 1273 (Ohio Supreme Court, 1984)
In re Murray
556 N.E.2d 1169 (Ohio Supreme Court, 1990)
In re Hayes
679 N.E.2d 680 (Ohio Supreme Court, 1997)
In re Z.C.
2023 Ohio 4703 (Ohio Supreme Court, 2023)

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Bluebook (online)
In re R.H., Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-rh-ohioctapp-2026.