In re Adoption of T.D.A.

2025 Ohio 4548
CourtOhio Court of Appeals
DecidedSeptember 30, 2025
Docket31331
StatusPublished

This text of 2025 Ohio 4548 (In re Adoption of T.D.A.) 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 T.D.A., 2025 Ohio 4548 (Ohio Ct. App. 2025).

Opinion

[Cite as In re Adoption of T.D.A., 2025-Ohio-4548.]

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

IN RE: ADOPTION OF T.D.A. C.A. No. 31331

APPEAL FROM JUDGMENT ENTERED IN THE COURT OF COMMON PLEAS COUNTY OF SUMMIT, OHIO CASE No. 2023 AD 072

DECISION AND JOURNAL ENTRY

Dated: September 30, 2025

FLAGG LANZINGER, Presiding Judge.

{¶1} Appellant Biological Mother (“Mother” or alternatively “Respondent”) appeals the

judgment of the Summit County Court of Common Pleas, Probate Division, that dismissed

Appellee’s (“Petitioner”) petition to adopt T.D.A. but declared that Petitioner is the child’s parent.

This Court vacates the judgment and remands for the probate court’s consideration of the issues

raised in Petitioner’s objection to the magistrate’s decision that dismissed her petition.

I.

{¶2} Mother is the biological mother of T.D.A., born July 31, 2019. The child was

conceived using donor sperm while Mother and Petitioner were in a committed domestic

relationship but not yet married. The parties married when the child was five months old. The

family was living in Florida at the time.

{¶3} A couple years later, the family relocated to Summit County, Ohio. Petitioner

wanted to adopt T.D.A., so she and Mother began to pursue that. Mother executed a consent to 2

adoption form and Petitioner filed a petition to adopt the child. The petition identified the child as

Petitioner’s stepson.

{¶4} The probate court ordered a home study. The assessor approved the parties’ home

and recommended that Petitioner be allowed to adopt the child. The probate court set the matter

for a hearing. Six days before the hearing, however, Mother moved to withdraw her consent and

to cancel the hearing on the adoption petition.

{¶5} Mother moved to dismiss the petition pursuant to Civ.R. 12(B)(6). She argued that

Petitioner was not a person who may adopt the child under R.C. 3107.03(D)(1) as then in effect

because, although Petitioner and Mother were married and Petitioner was seeking to adopt as a

stepparent, Mother no longer supported the adoption. After a hearing on Mother’s motion to

dismiss, the magistrate issued a decision concluding that the case could not proceed under then-

current R.C. 3107.03(D)(1) absent Mother’s support. The magistrate dismissed the petition.

{¶6} Petitioner filed objections. She requested that the probate court reinstate her

stepparent petition to adopt the child. Petitioner argued that, while Mother need only support the

adoption, she chose to execute a consent to adoption form to indicate her support. Mother then

moved to withdraw her consent. Therefore, because Mother chose to subject herself to the R.C.

Chapter 3107 standards applicable to the withdrawal of consent, Petitioner argued that Mother had

to prove pursuant to R.C. 3107.084(B) that her withdrawal of consent was in the best interest of

the child. Instead, the magistrate had concluded that because Mother only had to support the

adoption and not consent to it, the statutory best interest consideration was not applicable.

Petitioner went on to argue that the evidence adduced at the hearing supported a finding that

adoption was in the child’s best interest so that allowing Mother to withdraw her consent was not. 3

Significantly, Petitioner never argued that she was anything other than the child’s stepparent, i.e.,

that she was T.D.A.’s legal or natural parent.

{¶7} The probate court neither expressly sustained nor overruled Petitioner’s objections.

Instead, the trial court agreed with the magistrate that the court must dismiss the petition, albeit on

alternative grounds. After reviewing case law discussing the various ways parenthood might be

established, e.g., via declaration of parentage; insemination; in vitro fertilization; and surrogacy,

the probate court declared that Petitioner was the child’s “natural parent who has not previously

terminated her parental rights.” Based on that holding, the probate court dismissed Petitioner’s

“step parent” petition to adopt.

{¶8} Mother timely appealed, raising two assignments of error for review. Because our

resolution of the first assignment of error is dispositive, this Court declines to address the second

assignment of error.

{¶9} As a preliminary matter, we note that Petitioner has moved to dismiss the appeal,

arguing that Mother lacks standing to appeal because she prevailed below, having obtained the

precise relief she requested, specifically dismissal of the petition. This Court deferred the motion

for determination during our disposition of the appeal. Magistrate’s Order, In re Adoption of

T.D.A., C.A. No. 31331 (9th Dist. June 6, 2025). Because the probate court did not merely dismiss

the petition but also declared Petitioner’s status as a natural parent of the child, Mother is an

aggrieved party with standing to appeal.

An appeal lies only on behalf of the party who is aggrieved by the judgment. The sole purpose of an appeal is to provide the appellant an opportunity to seek relief in the form of a correction of errors of the lower court that injuriously affected [her]. The test of the right to appeal lies in whether or not one is an aggrieved party – a party who has suffered some loss. 4

(Internal citations and quotations omitted) In re A.L.W., 2016-Ohio-911, ¶ 24 (9th Dist.). Because

it is our duty to decide actual controversies on appeal, i.e., rendering opinions that grant or deny

effective relief to the appellant, this Court may not make any determinations or address any issues

that will not impact or affect the matter before us. In re R.S., 2017-Ohio-2835, ¶ 22. On the other

hand, “[a]n appellant whose rights or interests have been adversely affected by a lower court’s

final order is an aggrieved party and has standing to file an appeal.” Willis v. Farmers Ins. of

Columbus, Inc., 2019-Ohio-516, ¶ 7 (9th Dist.), citing In re Estate of Shepherd, 1999 WL 312378,

*1 (9th Dist. May 5, 1999).

{¶10} In this case, Petitioner sought to adopt T.D.A. in order to acquire all parental rights

and responsibilities accorded to a natural parent. Mother opposed Petitioner’s adoption of the

child precisely because it would have placed Petitioner in the same position as Mother as T.D.A.’s

legal parent. Although the probate court dismissed the petition for adoption, it affirmatively

declared Petitioner to be the child’s natural parent, effectively granting Petitioner the precise relief

she sought contrary to Mother’s wishes. Under these circumstances, Mother is aggrieved by the

trial court’s judgment. Appellee-Petitioner’s motion to dismiss the appeal is denied.

II.

ASSIGNMENT OF ERROR I

THE TRIAL COURT COMMITTED REVERSIBLE ERROR BY FINDING THAT [PETITIONER] WAS THE PARENT OF THE MINOR CHILD ALTHOUGH THAT ISSUE WAS NOT PRESENTED EITHER BEFORE THE MAGISTRATE OR ON OBJECTION.

{¶11} Mother argues that the probate court erred, notwithstanding its dismissal of the

petition, by declaring that Petitioner is T.D.A.’s natural parent because that issue was not before

the court for consideration or determination. This Court agrees.

{¶12} The Supreme Court of Ohio recently reiterated: 5

[O]ur judicial system relies on the principle of party presentation, and courts should ordinarily decide cases based on issues raised by the parties. Epcon Communities Franchising, L.L.C. v. Wilcox Dev. Group, L.L.C., 2024-Ohio-4989, ¶ 15, citing Greenlaw v.

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Related

Greenlaw v. United States
554 U.S. 237 (Supreme Court, 2008)
In re A.L.W.
2016 Ohio 911 (Ohio Court of Appeals, 2016)
In re R.S.
2017 Ohio 2835 (Ohio Court of Appeals, 2017)
Willis v. Farmers Ins. of Columbus, Inc.
2019 Ohio 516 (Ohio Court of Appeals, 2019)
Snyder v. Old World Classics, L.L.C.
2025 Ohio 1875 (Ohio Supreme Court, 2025)

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Bluebook (online)
2025 Ohio 4548, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-adoption-of-tda-ohioctapp-2025.