In re Howard

In In re Howard (1997), 119 Ohio App.3d 201, 695 N.E.2d 1, the principal case for the proposition that "when a parent does speak against a child's penal interest, a colorable claim of a conflict is at least raised, "the court concluded there was no conflict. The court noted that "nothing in the record suggestedthat the juvenile's mother was acting other than in the juvenile's best interest" and that the juvenile "was represented by counsel throughout the proceedings." Id. at 207.