In re Adoption of J.G.S.

2023 Ohio 1155
CourtOhio Court of Appeals
DecidedApril 7, 2023
DocketC-220534
StatusPublished
Cited by4 cases

This text of 2023 Ohio 1155 (In re Adoption of J.G.S.) 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 J.G.S., 2023 Ohio 1155 (Ohio Ct. App. 2023).

Opinion

[Cite as In re Adoption of J.G.S., 2023-Ohio-1155.]

IN THE COURT OF APPEALS FIRST APPELLATE DISTRICT OF OHIO HAMILTON COUNTY, OHIO

IN RE: ADOPTION OF J.G.S. : APPEAL NO. C-220534 TRIAL NO. 2021000200 :

:

: O P I N I O N.

Appeal From: Hamilton County Court of Common Pleas, Probate Division

Judgment Appealed From Is: Affirmed

Date of Judgment Entry on Appeal: April 7, 2023

James J. Whitfield, for Appellant Father,

Mark C. Epply for Appellee C.S. OHIO FIRST DISTRICT COURT OF APPEALS

BOCK, Judge.

{¶1} Appellant Father challenges the adoption of his birth son, J.G.S., by

appellee C.S. In two assignments of error, Father contends that the adoption was

contrary to J.G.S.’s best interest under R.C. 3107.161. We disagree, overrule his

assignments of error, and affirm the probate court’s judgment.

I. Facts and Procedure

{¶2} When J.G.S. was born in 2011, his birth parents were unmarried. Three

months later, Father left the picture amidst substance-abuse issues and periods of

incarceration. Mother also struggled with substance-abuse issues of her own and

spells of incarceration. When he was three years old, J.G.S.’s maternal grandmother

was granted legal custody over him. But when she, too, became incarcerated in 2016,

Mother’s childhood friend C.S. was awarded custody of J.G.S. At the time, Father was

incarcerated and Mother failed to appear at the custody hearing.

{¶3} In January 2021, C.S. petitioned to adopt eight-year-old J.G.S. Weeks

later, Mother objected to the adoption. Roughly seven months later, Father’s attorney

filed a notice of appearance. After a hearing, the magistrate found that Father’s and

Mother’s consent was not necessary to proceed with the adoption.

{¶4} Father objected to the magistrate’s decision, arguing that his consent

was required under Ohio’s adoption laws. The probate court overruled Father’s

objections. First, the court noted that Father had been served with notice of the

adoption petition and failed to file an objection, obviating the need for his consent

under R.C. 3107.07(K). Second, the court found that Father had failed, without

justifiable cause, to provide for the maintenance and support of J.G.S. in the one-year

period before his placement with C.S. and the one-year period before C.S. petitioned

for adoption. See R.C. 3107.07(A). Third, the probate court found that Father lacked 2 OHIO FIRST DISTRICT COURT OF APPEALS

justifiable cause due to his failure to maintain de minimis contact with J.G.S. in the

year before his placement with C.S. and the year before C.S. filed the adoption petition.

See id. Neither Mother nor Father appealed the probate court’s R.C. 3107.07

determination that their consent to J.G.S.’s adoption was unnecessary.

{¶5} Next, the magistrate held two best-interest hearings, where C.S., C.S.’s

father, Father, and Mother testified. In addition, the parties presented Facebook

messages between the parties and the child, photographs, an Ohio Department of Job

and Family Services (“ODJFS”) adoption assessment, and legal documents. The

evidence established that J.G.S. successfully integrated into and bonded with C.S.’s

family. By all accounts, J.G.S. and C.S.’s two daughters considered one another

siblings. J.G.S. knew C.S.’s father as “pawpaw.” J.G.S. was doing well in school and in

the community—he was a successful fifth grader with plenty of friends and hobbies.

{¶6} The evidence also demonstrated that both Father and Mother had

worked hard to rehabilitate themselves, recover from their addictions, and restore a

sense of stability in their lives. Yet, Father’s and Mother’s testimony revealed a lack of

involvement in, and knowledge of, J.G.S.’s life. Father accepted responsibility for

leaving J.G.S. in the first months of his life. He explained that he now was sober and

wanted to be in his son’s life. The evidence indicates that he began paying some child

support in 2020 and filed for custody of his son after C.S. filed the adoption petition.

Similarly, Mother had achieved sobriety and established a family of her own.

{¶7} Both Father and Mother testified that they were prevented from having

any contact with J.G.S. after 2016. Facebook messages in the record show that C.S.

periodically spoke with Father, telling him about J.G.S. and informing him that J.G.S.

was curious about Father. The conversations occasionally became contentious. C.S.

acknowledged as much but was concerned with Father’s reliability and the potential 3 OHIO FIRST DISTRICT COURT OF APPEALS

impact on J.G.S.’s mental and emotional health. In addition, the record includes

Facebook messages from J.G.S. to Mother, where J.G.S. told her that he loved her and

missed her. Mother recalled a subsequent emotional and tearful 12-minute video call.

{¶8} In an in-camera interview, J.G.S. described feeling “very happy” with

C.S. and her daughters, who he referred to as his “mom” and his “sisters.” He felt close

to everyone in C.S.’s family, and importantly, felt safe. He liked his school and had

established friendships. He unequivocally wanted to be adopted and acknowledged

the possibility that he may lose contact with his birth parents if he were adopted.

{¶9} Following the hearing, the magistrate analyzed the relevant best-

interest factors under R.C. 3107.161(B) and found that granting the adoption petition

was in J.G.S.’s best interest. The magistrate incorporated all previous findings,

recounted J.G.S.’s custodial history and described C.S.’s continued care of J.G.S. The

magistrate acknowledged Mother’s and Father’s rehabilitation and increased stability,

as well as their testimony emphasizing the need for J.G.S. to know his family history.

But the magistrate noted that Mother and Father both failed to appear at the 2016

custody hearing and were unaware of who had custody of their son. Further, Father

had no contact with J.G.S. and paid no support until 2019. And both Mother and

Father admitted that they knew nothing about J.G.S. Likewise, J.G.S. had no memory

of Father and expressed a clear desire to be adopted. Ultimately, the stability and

permanence of C.S.’s family weighed in favor of adoption because J.G.S. “will feel more

like he is part of the family unit after the adoption” and will not be scared that “one of

his parents might file for custody and take him away from the home that he knows.”

{¶10} The magistrate rejected Father’s argument that J.G.S.’s placement with

C.S. was not the least-detrimental alternative available. While the magistrate found

Father’s and Mother’s desire to be in J.G.S.’s life sincere, they failed to show that being 4 OHIO FIRST DISTRICT COURT OF APPEALS

adopted by C.S. was not the least-detrimental alternative. Rather, C.S. provided safety

and stability, and J.G.S. lacked a relationship with his birth parents. The magistrate

explained that adoption is “not about the best interest of the biological parents and the

effects on them,” and their desires were outweighed by the substantial benefits that

C.S.’s day-to-day influence would provide to J.G.S.

{¶11} Father objected. The probate court overruled his objection and adopted

the magistrate’s findings of fact and conclusions of law. The court found that the

adoption was in J.G.S.’s best interest under R.C. 3107.161 because “[n]either [Father]

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Cite This Page — Counsel Stack

Bluebook (online)
2023 Ohio 1155, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-adoption-of-jgs-ohioctapp-2023.