In re Lay

In In re Lay (1987), 43 Ohio App.3d 78, 539 N.E.2d 664, the mother attended parenting classes, but made little progress; permitted her emotional needs to take precedence over her desire to provide parental care to her child; and was generally unable to place the safety and well-being of her child above her own emotional needs. Lay, 43 Ohio App.3d at 82. Although the mother made some progress in her ability to take care of her own needs, there was no evidence that she would be able to care for her child in the near future. Id. The decisional point for the reviewing court, however, was the progress of the father. The court found significant evidence that the father made every effort to be the best father he could. Id. He benefitted from parenting classes and from money management assistance. Id. There had been a "marked improvement" in his parenting skills and living arrangements. Id. Although the father was said to require substantial support from outside agencies, there was also evidence in the record that there were community agencies that could provide the needed support. Id.