In Re Vickers Children

Ohio Court of Appeals

Decided December 30, 1983

Ohio Court of Appeals · decided 1983-12-30

Good law ✅— No negative treatment on recordhow we know

Decided 1983-12-30

How this case has been cited

Cited by 45 later decisions — most recently September 2025 · most notably 36 Ohio App. 3d 123 - In Re Bishop (1987), 83 Ohio App. 3d 869 - In Re Brofford (1992)

45 state decisions

Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.

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Hendrickson, P.J.,

¶1 concurring. Although I must concur with the majority that the evidence in case No. CA83-06-071 is so overwhelming that the decision to divest Diane Vickers Pate of all parental rights, privileges and responsibilities must be affirmed, I cannot condone the failure of the trial court to follow the Rules of Juvenile Procedure. Juv. R. 29 requires an adjudicatory hearing, and Juv. R. 34 requires a separate dispositional hearing. Therefore, the failure to conduct two separate hearings is clearly error. It follows that although we were unable to find any prejudice to Mrs. Pate in the case sub judice, the failure to conduct a bifurcated hearing is always suspect. After all, we cannot always determine from the record before us that a shortcut in procedure was harmless error.

¶2 In case No. CA83-06-072, I concur with the majority in the disposition of both assignments of error.