In re Adoption of A.W.C.

2024 Ohio 2762
CourtOhio Court of Appeals
DecidedJuly 22, 2024
Docket24AP0001
StatusPublished

This text of 2024 Ohio 2762 (In re Adoption of A.W.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.W.C., 2024 Ohio 2762 (Ohio Ct. App. 2024).

Opinion

[Cite as In re Adoption of A.W.C., 2024-Ohio-2762.]

STATE OF OHIO ) IN THE COURT OF APPEALS )ss: NINTH JUDICIAL DISTRICT COUNTY OF WAYNE )

IN RE: ADOPTION OF A.W.C. C.A. No. 24AP0001

APPEAL FROM JUDGMENT ENTERED IN THE COURT OF COMMON PLEAS COUNTY OF WAYNE, OHIO CASE No. 2023 PB-A 000727

DECISION AND JOURNAL ENTRY

Dated: July 22, 2024

SUTTON, Judge.

{¶1} Appellant Mother appeals the judgment of the Wayne County Court of Common

Pleas, Probate Division, that found that her consent to the adoption of her biological child was not

required based on her failure to object to the Appellees-Petitioners’ petition for adoption. This

Court affirms.

I.

{¶2} Mother and Father are the biological parents of A.W.C. (“A.C.”), born on June 26,

2014. In 2020, Wayne County Children Services Board filed a complaint in the Wayne County

Juvenile Court regarding A.C. and his two siblings. In March 2022, Mother and Father waived

their rights to the final dispositional hearing and stipulated that A.C. be placed in the legal custody

of his then-foster parents, Mr. and Mrs. C. The juvenile court ordered each parent to pay child

support and left visitation in the sole discretion of the legal custodians. By further agreement of

the parties, the juvenile court awarded legal custody of the two siblings to a maternal relative. 2

{¶3} On July 3, 2023, Mr. and Mrs. C. (aka “Petitioners”) filed a petition to adopt A.C.

They alleged that Mother’s and Father’s consent to adoption was not required pursuant to R.C.

3107.07(A) based on their failures to have contact with or provide support for the child during the

one-year period prior to the filing of the petition. The probate court scheduled a hearing on the

petition and attempted to notify the parents of the hearing and filing of the petition by certified

mail. The post office returned the notices to the probate court as undeliverable based on incorrect

addresses for the parents.

{¶4} The probate court again attempted to provide the required notification to the parents

by certified mail at their current addresses. This time delivery was successful. Father signed for

receipt of the notice on August 31, 2023; while Mother signed for receipt of the notice on

September 15, 2023. The probate court noted proof of service on Father and Mother on its docket

on September 13 and 20, respectively. The notice included the statutory warning in bold, all capital

typeface regarding the requirement to file an objection to the petition within 14 days after proof of

service of notice if the parent wished to contest the adoption. Father never filed an objection to

the petition, and he has not appealed.

{¶5} On October 12, 2023, an attorney filed a notice of appearance on behalf of Mother,

but no other documents at that time. On October 31, 2023, Mother filed a motion for leave to

plead, seeking leave to file an untimely objection to the petition for adoption. In support, Mother

asserted that she went to the office of the probate clerk of court within 14 days to ask what she

needed to do to make her objection known. She asserted that the clerk did not advise her as to

what she should do or that she could apply for appointed counsel. Mother further wrote that she

tried to retain counsel but was not immediately successful. She admitted that her retained counsel

filed a notice of appearance 21 days after the probate court docketed proof of service of notice on 3

her. Finally, she asserted that the untimely filing of her objection would not prejudice Petitioners

because they were aware that she did not consent to the adoption. Mother failed to challenge the

constitutionality of any provisions in the adoption statute.

{¶6} On November 2, 2023, Petitioners moved for an order finding that Mother’s and

Father’s consent to adoption was unnecessary under R.C. 3107.07(K), which obviates the need for

the consent of any person who was properly notified of the hearing and filing of the petition yet

failed to file an objection within 14 days after proof of notice was filed. Although Mother moved

for an extension of time to file a response to Petitioners’ motion, and the probate court granted her

leave to do so, Mother failed to file a response.

{¶7} Subsequently, the probate court issued a judgment finding that the parents’ consent

to the adoption of A.C. was not required due to their failures to timely file objections to the petition.

Mother timely appealed and raises three assignments of error for review. This Court consolidates

some assignments of error. The probate court stayed its judgment pending appeal.

II.

ASSIGNMENT OF ERROR I

[R.C.] 3107.07(K) VIOLATES THE 14TH AMENDMENT TO THE UNITED STATES CONSTITUTION, AS APPLIED TO APPELLANT’S CASE AND OTHERS SIMILARLY SITUATED, BY ARBITRARILY DENYING APPELLANT EQUAL PROTECTION AND [HER] DUE PROCESS RIGHT TO BE HEARD AT A MEANINGFUL TIME AND IN A MEANINGFUL MANNER ON THE PETITION FOR ADOPTION.

ASSIGNMENT OF ERROR II

THE HEARING NOTICE CONTAINED IN [R.C.] 3107.11(B) VIOLATES APPELLANT’S CONSTITUTIONAL RIGHT TO DUE PROCESS AS THE NOTICE PROVISION IS CONFUSING, MISLEADING AND INACCURATE. 4

{¶8} Mother argues that R.C. 3107.07(K) and R.C. 3107.11(B) are unconstitutional

because the former violates equal protection, and the latter violates due process. This Court

declines to address her arguments.

{¶9} It is well settled that we need not reach constitutional challenges on appeal that the

appellant failed to timely raise in the trial court. In re Adoption of M.L.M., 2023-Ohio-1876, ¶ 16

(9th Dist.), quoting In re N.L., 2015-Ohio-4165, ¶ 51 (9th Dist.). Mother did not challenge the

constitutionality of either statutory provision below. Instead, she moved for leave to file her

untimely objection to the adoption petition because the probate clerk of court did not give her

advice regarding how to proceed and she was unable to secure retained counsel within 14 days of

service of notice. Because Mother did not raise or develop her current constitutional arguments in

the probate court, this Court declines to address them now in the first instance. Mother’s first and

second assignments of error are overruled.

ASSIGNMENT OF ERROR III

THE PROBATE COURT ERRED WHEN IT DID NOT CONDUCT A CONSENT HEARING.

{¶10} Mother argues that the probate court erred by failing to hold a consent hearing to

determine whether she had a “valid reason” for failing to file a timely objection to the petition for

adoption. This Court disagrees.

{¶11} R.C. 3107.07(K) provides that “[c]onsent to adoption is not required” when a

“person given notice of the petition pursuant to division (A)(1) of section 3107.11 of the Revised

Code [ ] fails to file an objection to the petition within fourteen days after proof is filed pursuant

to division (B) of that section that the notice was given[.]” Mother admits that she did not file a

timely objection. “While the result may be harsh, the plain language of R.C. 3107.07(K) imposes

a strict 14-day window in which a parent may file an objection to a petition for adoption after proof 5

of notice and provides no authority for the probate court to extend that deadline irrespective of

whether the trial court might find good cause for an extension.” In re Adoption of G.W.K., 2022-

Ohio-2620, ¶ 21. Because Mother received proper notice and the probate court had no discretion

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Related

In re N.L.
2015 Ohio 4165 (Ohio Court of Appeals, 2015)
In re Adoption of M.L.M.
2023 Ohio 1876 (Ohio Court of Appeals, 2023)

Cite This Page — Counsel Stack

Bluebook (online)
2024 Ohio 2762, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-adoption-of-awc-ohioctapp-2024.