In re Thompkins

{¶ 30} The overriding issue in this fact-intensive case is whether appellant, Montgomery County Children Services (“MCCS”), exercised “reasonable diligence” under Juv.R. 16(A) in attempting to serve appellee Iler Crawford with notice of a hearing in which his parental rights were at stake. In my view, the majority unjustifiably limits its analysis of that issue by resolving it solely within the narrow confines of a discussion of the requirements of Civ.R. 4.6(D). But this case also presents this court with an opportunity to clarify the standards that should apply to similar situations in the…