In Re Z.R.

{¶ 1} In this appeal, we address whether the failure to establish proper venue in a child-dependency complaint requires a juvenile court to dismiss the complaint due to lack of jurisdiction. We hold that the statute and rule governing venue do not control the jurisdiction of a juvenile court and that a dismissal for improper venue therefore cannot be entered on jurisdictional grounds.

Relevant Background

{¶ 2} L.R. is the biological mother of six children, including Z.R., her youngest child. L.R.’s five older children were removed from her custody and were adjudicated dependent and neglected on…