In re Cunningham

In In re Cunningham, Athens App. No. 03CA26, 2004 Ohio 787, the appellee father relatively quickly had undergone substance abuse counseling, acquired a home, and obtained employment. In light of these rapid improvements, the trial court refused to allow the State to terminate his parental rights without first giving him an opportunity to satisfy his own personal case plan. Because the father had not received such an opportunity, the trial court overruled the State's motion for permanent custody and the Fourth District affirmed. Notably, only about one and a half years had passed in Cunningham between the award of temporary custody to the State and the trial court's denial of the motion for permanent custody.