What Factors Should Be Balanced In Determining Whether Parent's Due Process Rights Are Being Violated If Permanent Custody Hearing Is Held In His Absence ? In In re Jesse P., 6th Dist. No. L-04-1028, 2004 Ohio 3801, the Court held that a trial court should balance the competing interests at stake in the proceedings to determine whether a parent's due process rights would be violated by holding the permanent custody hearing in their absence. "Specifically, a court should balance the following factors: '(1) the private interest affected; (2) the risk of erroneous deprivation and the probable value of additional safeguards; (3) the governmental burden of additional procedural safeguards.'" Jesse at P 51, citing In re Sprague, 113 Ohio App.3d 274, 276, 680 N.E.2d 1041.