In re Adoption of A.E.C.

2024 Ohio 5559
CourtOhio Court of Appeals
DecidedNovember 25, 2024
Docket16-24-10
StatusPublished
Cited by2 cases

This text of 2024 Ohio 5559 (In re Adoption of A.E.C.) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re Adoption of A.E.C., 2024 Ohio 5559 (Ohio Ct. App. 2024).

Opinion

[Cite as In re Adoption of A.E.C., 2024-Ohio-5559.]

IN THE COURT OF APPEALS OF OHIO THIRD APPELLATE DISTRICT WYANDOT COUNTY

IN RE: THE ADOPTION OF: CASE NO. 16-24-10

A.E.C.

[BENNY B. - APPELLANT] OPINION

Appeal from Wyandot County Common Pleas Court Probate Division Trial Court No. 20225011

Judgment Affirmed

Date of Decision: November 25, 2024

APPEARANCES:

Howard A. Elliott for Appellant

Kelle M. Saull for Appellee Case No. 16-24-10

WALDICK, J.

{¶1} Respondent-appellant, Benny B. (“Benny”), appeals the May 20, 2024

judgment of the Wyandot County Common Pleas Court, Probate Division, in which

the trial court granted a final order of adoption of Benny’s minor daughter,

“A.E.C.”, after finding that Benny’s consent was not required for the adoption. For

the reasons set forth below, we affirm.

Procedural History

{¶2} On July 18, 2022, petitioners-appellees, Scott C. (“Scott”) and Lisa C.

(“Lisa”), filed a petition pursuant to R.C. 3107.05 for adoption of A.E.C., who was

born in 2017 and is the biological daughter of Erin S. (“Erin”) and Benny. 1 The

petition asserted that Erin’s consent to the adoption was required, and a written

consent to the adoption signed by Erin was filed with the petition. The petition

further asserted that Benny’s consent was not required for the

adoption. Specifically, the petition alleged that Benny had failed without justifiable

cause to provide more than de minimis contact with the child for a period of at least

one year immediately preceding the filing of the adoption petition, and also that

Benny had failed without justifiable cause to provide for the maintenance and

1 While this case was captioned in the trial court from the beginning as “In the Matter of the Adoption of A.E.C.”, as required by R.C. 3107.04(C), the child’s initials were actually A.E.S. at the time the petition was filed. The petition requested that the child’s name be changed to A.E.C. as part of the adoption, and that name change was ultimately ordered by the trial court when the adoption was granted. To be consistent with the case caption, and in light of the subsequently ordered name change, we refer to the child as “A.E.C.” throughout this opinion.

-2- Case No. 16-24-10

support of the child as required by law or judicial decree for at least that same time

period.

{¶3} On January 3, 2023, Benny filed a handwritten letter with the court,

objecting to the petition seeking to adopt his daughter. On January 17, 2023,

counsel filed a formal objection to the adoption on Benny’s behalf.

{¶4} On November 17, 2023, an evidentiary hearing was held on the issue of

whether Benny’s consent was required for the adoption.

{¶5} On November 22, 2023, Benny filed a “Submission of Supplemental

Case Law.” In that filing, Benny asserted that his purported failure to provide

support for A.E.C. was justified due to a “zero-support” court order in Allen County,

Ohio, and cited to In re Adoption of B.I., 2019-Ohio-2450, in support of his

position. Benny further asserted that his purported failure to provide more than de

minimis contact with A.E.C. was justified due to Scott and Lisa requesting through

A.E.C.’s paternal grandmother that Benny not have contact with, or be known to,

the child.

{¶6} On November 27, 2023, Scott and Lisa filed a response with citations

to a number of Ohio court decisions in support of their position that Benny’s consent

was not required.

{¶7} On December 5, 2023, the probate court filed a judgment entry finding

that Benny’s consent to the adoption was not required. The probate court based that

decision on two alternative findings: (1) that Benny had failed without justifiable

-3- Case No. 16-24-10

cause to provide more than de minimis contact with A.E.C. as alleged in the petition,

and (2) that Benny had failed to provide for the maintenance and support of A.E.C.

as required by law or judicial decree, as also alleged in the petition.

{¶8} On May 7, 2024, an evidentiary hearing was held on the issue of

whether the adoption was in the best interest of A.E.C. At the conclusion of that

hearing, the probate court ruled from the bench that adoption was in the best interest

of A.E.C.

{¶9} On May 20, 2024, the probate court filed a final decree of adoption. In

that decree, the court found that adoption was in the best interest of the child and

granted the petition for adoption. On June 5, 2024, the probate court filed a nunc

pro tunc final decree of adoption, in order to correct an erroneous case number on

the May 20, 2024 decree.

{¶10} On June 12, 2024, Benny filed the instant appeal, in which he raises

three assignments of error for our review.

First Assignment of Error

The trial court committed reversible error requiring the setting aside of the adoption decree herein and the remand to the trial court for further proceedings by holding that the father’s consent to the adoption petition was not required by finding that he had failed to provide for the maintenance and support of the child as required by law and judicial decree for a period of one year immediately preceding the filing of the adoption petition.

Second Assignment of Error

The trial court committed error requiring the court to set aside the adoption petition and remand to the trial court for further -4- Case No. 16-24-10

proceedings by finding that father’s consent was not necessary to the petition for adoption because he had failed without justifiable cause to provide more than de minimis contact with the child for a one-year period of time prior to the filing of the adoption petition.

Third Assignment of Error

The trial court committed reversible error requiring the court to set aside the ruling of the adoption petition and remand these proceedings to the trial court by finding the best interest of the child is best served by the granting of the adoption petition.

{¶11} Because our resolution of the second assignment of error renders the

first assignment of error moot, we elect to address the assignments of error out of

the order in which they are raised.

{¶12} In the second assignment of error, Benny argues that the trial court

erred in finding that Benny’s consent to the adoption was not required on the basis

that he had failed without justifiable cause to have more than de minimis contact

with the child for the one-year period preceding the filing of the adoption petition.

{¶13} On appeal, Benny appears to concede that he did not have more than

de minimis contact with A.E.C. for the one-year period prior to the adoption petition

being filed, a concession that is supported by the record. However, Benny asserts

that his lack of contact with his daughter during that time period was justified and

that the trial court erred in finding otherwise.

-5- Case No. 16-24-10

{¶14} “[T]he right of a natural parent to the care and custody of his children

is one of the most precious and fundamental in law.” In re Adoption of Masa, 23

Ohio St.3d 163, 165 (1986). “Under most circumstances, both of a minor’s natural

parents must provide written consent prior to the adoption of that minor.” In re

Adoption of S.S., 2017-Ohio-8956, ¶ 16 (3d Dist.).

{¶15} However, R.C. 3107.07 sets forth exceptions to that general rule

regarding consent. R.C. 3107.07(A), the exception relevant here, provides:

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Cite This Page — Counsel Stack

Bluebook (online)
2024 Ohio 5559, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-adoption-of-aec-ohioctapp-2024.