In re Adoption of E.G.B.

2025 Ohio 3005
CourtOhio Court of Appeals
DecidedAugust 22, 2025
Docket30432 & 30433
StatusPublished
Cited by1 cases

This text of 2025 Ohio 3005 (In re Adoption of E.G.B.) 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 E.G.B., 2025 Ohio 3005 (Ohio Ct. App. 2025).

Opinion

[Cite as In re Adoption of E.G.B., 2025-Ohio-3005.]

IN THE COURT OF APPEALS OF OHIO SECOND APPELLATE DISTRICT MONTGOMERY COUNTY

IN THE MATTER OF THE ADOPTION : OF E.G.B. AND L.R.B. : C.A. Nos. 30432; 30433 : : Trial Court Case Nos. 2024 ADP 00127; : 2024 ADP 00128 : : (Appeal from Common Pleas Court- : Probate Division) : : FINAL JUDGMENT ENTRY & OPINION ...........

Pursuant to the opinion of this court rendered on August 22, 2025, the judgment of

the trial court is affirmed.

Costs to be paid as stated in App.R. 24.

Pursuant to Ohio App.R. 30(A), the clerk of the court of appeals shall immediately

serve notice of this judgment upon all parties and make a note in the docket of the service.

Additionally, pursuant to App.R. 27, the clerk of the court of appeals shall send a certified

copy of this judgment, which constitutes a mandate, to the clerk of the trial court and note

the service on the appellate docket.

For the court,

MICHAEL L. TUCKER, JUDGE

EPLEY, P.J., and LEWIS, J., concur. -2- OPINION MONTGOMERY C.A. Nos. 30432; 30433

BLUE T. SULLIVAN, Attorney for Appellant JENNIFER S. GETTY, Attorney for Appellees

TUCKER, J.

{¶ 1} Appellant R.A.C. (“Mother”) appeals from a judgment of the Montgomery

County Court of Common Pleas, Probate Division, finding that her consent to the adoption

of her minor children was not required. For the reasons that follow, we affirm.

I. Factual and Procedural History

{¶ 2} Mother is the biological parent of E.G.B., born in August 2019, and L.R.B., born

in July 2020. The children have lived with their maternal grandfather and his wife (“the

grandparents”) since they were infants. The maternal grandfather was granted legal custody

of the children in May 2021.

{¶ 3} On September 23, 2024, the grandparents filed petitions for the adoption of

E.G.B. and L.R.B. In the petitions, the grandparents alleged Mother’s consent was not

needed because she failed without justifiable cause to (1) have more than de minimis

contact with the children, and (2) provide maintenance or support for the children. On the

same day, the grandparents filed instructions for service and notice of hearing upon Mother.

The clerk of courts mailed the service and notice by FedEx Corporation on September 24,

2024. Mother received, and signed for, the notices on September 30, 2024.

{¶ 4} On November 3, 2024, counsel entered an appearance on behalf of Mother in

both adoption cases and filed a motion for extension of time to file objections to the petitions.

The motion stated: -3- Upon being served Mother sought assistance from the Ohio Domestic

Violence Network (“ODVN”) to obtain legal counsel in this matter as she is

represented through ODVN in [an accompanying matter]. Upon learning

ODVN could not assist her as this is an adoption matter, Mother immediately

sought private counsel who is now seeking an extension to file the attached

Objection as Mother does not consent to the adoption.

{¶ 5} On the same day, Mother filed objections to the adoptions in which she denied

the allegations that she had failed to provide more than de minimis contact with the children

and that she had failed to provide support for the children. The motion for extension was

denied on November 21, 2024.

{¶ 6} On November 22, 2024, the court held a telephone conference with counsel. It

then ordered Mother to “file a statement with the Court identifying whether service of notice

of hearing on the petitions were [sic] insufficient and if so, state with particularity the reasons

in support of any insufficiency of service.” On December 2, 2024, Mother filed a document

entitled “Service Statement” in which she alleged that the service of process was insufficient

because she “did not receive Form 18.2, which contains the notice [of the need to file

objections to the adoption action within 14 days as] required by R.C. 3107.11.”

{¶ 7} A hearing on the issues of service and consent was held on February 20, 2025.

Mother testified that she had received and signed for a package from FedEx. She further

testified that she had read the papers and then sent messages via Facebook to her father.

Mother testified that she and her mother, with whom she was living, had reviewed the papers

that evening. She also testified that she had not been aware that she was required to file

objections within 14 days because she did not receive such a notification. Specifically, she

testified that the notice sent by the clerk did not include the required page setting forth the -4- notice regarding the 14-day objection deadline. Mother immediately contacted her attorney

and texted her attorney a picture of the paperwork. According to Mother, her attorney told

her to contact ODVN regarding representation. Mother testified that she had contacted

ODVN and that it “took them two weeks to get back to her” to deny representation. It took

her another two weeks to gather enough money to be able to retain her attorney.

{¶ 8} The trial court found that Mother’s testimony lacked credibility and that she had

been properly notified of the need to file objections within 14 days of service. Because she

failed to do so, the trial court concluded that her consent to the adoptions was not needed.

{¶ 9} Mother appeals.

II. Consent to Adoption

{¶ 10} Mother’s sole assignment of error states as follows:

The trial court failed to follow the law by finding that Appellant’s consent is not

required, or it was against the manifest weight of the evidence for the trial court

to find the Appellant’s consent was not required.

{¶ 11} Mother contends the probate court’s decision was against the manifest weight

of the evidence and that it erred in concluding her consent was not required for the adoption

actions to proceed. In support, she argues the record demonstrates that her objections to

the adoptions were not untimely because she did not receive proper notice of the deadline

for filing objections.

{¶ 12} Under Ohio law, an adoption proceeding is a two-step process involving (1) the

consent phase and (2) the best interest phase. In re Adoption of J.A.M., 2022-Ohio-2313,

¶ 9 (2d Dist.). “[C]ertain persons [including the biological parents] must consent to an

adoption.” In re M.A.S., 2020-Ohio-3603, ¶ 14 (12th Dist.). A trial court’s finding that the -5- consent of a statutorily required party is not required is a final appealable order. In re

Adoption of Greer, 70 Ohio St.3d 293 (1994), paragraph one of the syllabus.

{¶ 13} There are exceptions to the consent requirement. In re M.A.S. at ¶ 14, citing

R.C. 3107.07. “As applicable to this case, these exceptions include a person whose consent

is required who fails to file an objection to the adoption petition within 14 days of proof of

service.” Id., citing R.C. 3107.07(K). “To implicate R.C. 3107.07(K), the notice must clearly

inform the recipient that he is required to file an objection to the petition within 14 days.” Id.

at ¶ 15.

{¶ 14} R.C. 3107.11 sets forth the requirements for notice in adoption cases. Of

relevance to this matter, the statute provides:

Upon the filing of a petition for adoption that alleges that a parent has failed

without justifiable cause to provide more than de minimis contact with the

minor or to provide for the maintenance and support of the minor, the clerk of

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Related

In re Adoption of F.M.W.
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2025 Ohio 5684 (Ohio Court of Appeals, 2025)

Cite This Page — Counsel Stack

Bluebook (online)
2025 Ohio 3005, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-adoption-of-egb-ohioctapp-2025.