In re Adoption of M.G.S.

2024 Ohio 322
CourtOhio Court of Appeals
DecidedJanuary 31, 2024
Docket30647
StatusPublished
Cited by1 cases

This text of 2024 Ohio 322 (In re Adoption of M.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 M.G.S., 2024 Ohio 322 (Ohio Ct. App. 2024).

Opinion

[Cite as In re Adoption of M.G.S., 2024-Ohio-322.]

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

IN RE: C.A. No. 30647

THE ADOPTION OF M.G.S.

APPEAL FROM JUDGMENT ENTERED IN THE COURT OF COMMON PLEAS COUNTY OF SUMMIT, OHIO CASE No. 2022 AD 002

DECISION AND JOURNAL ENTRY

Dated: January 31, 2024

STEVENSON, Judge.

{¶1} Appellant Father appeals the judgment of the Summit County Court of Common

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

necessary as his lack of contact with his child was not justified by mother’s alleged refusal to

permit him to communicate with her. This Court affirms.

I.

{¶2} Mother and Father are the natural parents of M.G.S., born March 26, 2012.

Although the parents were never married, Father established paternity at the time of the child’s

birth. Mother and Father ended their romantic relationship when their daughter was around a year

and a half old. Father filed an action in the domestic relations court seeking parenting time with

the child. He dismissed his case two weeks later after informing the domestic relations court that

he and Mother had reached an informal agreement as to visitation. 2

{¶3} Mother and Father each went on to marry other people. Father and his wife have

two children. M.G.S. has resided with Mother and Petitioner-Stepfather since 2016. On January

5, 2022, when the child was almost ten years old, Stepfather filed a petition to adopt the minor.

Mother consented to the adoption. Stepfather alleged that Father’s consent was not required

pursuant to R.C. 3107.07(A) because Father had failed to have more than de minimis contact with

the child without justifiable cause during the relevant statutory one-year lookback period.

Although Stepfather also alleged Father’s failure to provide maintenance and support for the child,

he later withdrew that allegation.

{¶4} Father filed an objection to the petition. After a hearing, the magistrate found that

Father had not had more than de minimis contact with M.G.S. during the relevant time period; that

he had no justifiable cause for his failure to maintain contact; and that his consent to the adoption

was, therefore, not required. Father timely objected to the magistrate’s decision; the probate court

overruled Father’s objection and ordered that Father’s consent to adoption of M.G.S. was not

required. Father timely appealed and raises one assignment of error for review.

II.

ASSIGNMENT OF ERROR

THE FINDINGS OF THE TRIAL COURT ARE AGAINST THE MANIFEST WEIGHT OF THE EVIDENCE[.]

{¶5} Father argues that the probate court’s finding that his consent to adoption of his

biological child was not required is against the manifest weight of the evidence. While he argues

that his limited contact with the child was meaningful, the crux of his argument is that he had

justifiable cause for having no more that de minimis contact with M.G.S. during the year prior to

Stepfather’s filing of his petition for adoption. This Court disagrees. 3

{¶6} Generally, the biological parents of a child must consent to the child’s adoption by

another person. R.C. 3107.06. R.C. 3107.07(A) provides exceptions to the parental consent

requirement “when it is alleged in the adoption petition and the court, after proper service of notice

and hearing, finds by clear and convincing evidence that the 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 as required by law or judicial decree for a period of at least one year

immediately preceding * * * the filing of the adoption petition[.]”1 As the statute is written in the

disjunctive, the failure of either contact or support will obviate the need for the respondent-parent’s

consent. In re Adoption of F.A., 9th Dist. Summit No. 27275, 2015-Ohio-2249, ¶ 8. Clear and

convincing evidence is evidence that will “produce in the mind of the trier of facts a firm belief or

conviction as to the facts sought to be established.” In re Adoption of Holcomb, 18 Ohio St.3d

361, 368 (1985).

{¶7} The Ohio Supreme Court has recently clarified that courts must apply a three-part

test to determine whether a respondent-parent’s consent to adoption is necessary, irrespective of

whether the petitioner has alleged unjustifiable failure to provide support or to maintain contact

with the child. In re Adoption of A.K., 168 Ohio St.3d 225, 2022-Ohio-350, ¶ 17. The original

inquiry was simply whether the petitioner established the two statutory elements. Id. at ¶ 16. Here,

that is whether Father failed to have more than de minimis contact with the child during the one-

year lookback period, and if so, whether justifiable cause existed for that failure. R.C. 3107.07(A).

{¶8} The recently added initial step requires the court to consider whether a law or court

order limited or curtailed the respondent-parent’s obligation regarding support or contact. In re

1 Section 3107.07(A) provides an alternative one-year lookback period preceding “the placement of the minor in the home of the petitioner[,]” which provision is not relevant to this case. 4

Adoption of A.K. at ¶ 17-18. In other words, “a probate court should not dispense with the

requirement of a parent’s consent when the parent abided by a court order prohibiting the parent

from doing the very act that the statute requires in order for the parent to maintain his or her right

to consent to the adoption of his or her minor child.” Id. at ¶ 18. In this way, a court order expressly

imposing no obligation on a parent to provide child support or precluding the parent’s contact with

the child would create “an automatic exemption from the trial court’s justifiable-cause analysis”

and end further analysis regarding whether the parent’s consent to adoption is necessary. Id. at ¶

14, 16.

{¶9} As to the first prong of the three-prong test, the Ohio Supreme Court recognized

that the exemption from the exception to the consent requirement would naturally be implicated

“when a [respondent-]parent can point to a court order that required no maintenance and support

[or no contact with the child] * * *.” Id. at ¶ 16-17. However, the petitioner who alleges an R.C.

3107.07(A) exception to the consent requirement bears the burden of proof to demonstrate both

(1) the failure to provide support or have more than de minimis contact with the child, and (2) that

there was not justifiable cause for the failure. In re Adoption of F.A., 2015-Ohio-2249, at ¶ 7. See

also In re A.L.H., 9th Dist. Medina Nos. 18CA0084-M and 18CA0085-M, 2020-Ohio-3527, ¶ 8

(“The burden of proof remains at all times with the petitioner to show by clear and convincing

evidence the lack of either the requisite contact or support, as well as the lack of justifiable cause.”).

This Court added:

Even so, in the face of evidence of a lack of the requisite contact or support, the respondent-parent may not simply remain mute, but must rather demonstrate some facially justifiable cause for the parent’s failure. Nevertheless, while the respondent-parent may acquire a burden of going forward, the ultimate burden of proof remains with the petitioner.

(Internal citations omitted) Id. 5

{¶10} Appellate review of the probate court’s determinations regarding the two statutory

elements is subject to different standards.

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Related

In re Adoption of S.G.L.
2024 Ohio 2248 (Ohio Court of Appeals, 2024)

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2024 Ohio 322, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-adoption-of-mgs-ohioctapp-2024.