In re Adoption of T.M.Z.

2025 Ohio 5000
CourtOhio Court of Appeals
DecidedNovember 3, 2025
Docket13-25-07
StatusPublished
Cited by1 cases

This text of 2025 Ohio 5000 (In re Adoption of T.M.Z.) 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.M.Z., 2025 Ohio 5000 (Ohio Ct. App. 2025).

Opinion

[Cite as In re Adoption of T.M.Z., 2025-Ohio-5000.]

IN THE COURT OF APPEALS OF OHIO THIRD APPELLATE DISTRICT SENECA COUNTY

IN RE: THE ADOPTION OF: CASE NO. 13-25-07

T.M.Z. OPINION AND [ANDREW W. - APPELLANT] JUDGMENT ENTRY

Appeal from Seneca County Common Pleas Court Probate Division Trial Court No. 20245020

Judgment Affirmed

Date of Decision: November 3, 2025

APPEARANCES:

Timothy J. Hoover for Appellant

Jennifer L. Kahler for Appellee Case No. 13-25-07

ZIMMERMAN, J.

{¶1} Biological father-appellant, Andrew W. (“Andrew”), appeals the

January 24, 2025 judgment of the Seneca County Court of Common Pleas, Probate

Division, granting a final order of adoption of Andrew’s minor child, T.M.Z., after

finding that his consent was not required because he failed without justifiable cause

to have contact with T.M.Z. for the one-year period immediately preceding the filing

of the adoption petition. For the reasons that follow, we affirm.

{¶2} T.M.Z. was born in 2018 to K.Z. (“Mother”) and Andrew, who were

not married. Andrew lived with Mother for approximately six weeks after T.M.Z.’s

birth. Shortly thereafter, Andrew and Mother’s relationship ended.

{¶3} The last time Andrew saw T.M.Z. was in April of 2019.

{¶4} Mother started dating Z.Z. (“Stepfather”) in early 2019 and they

married in 2023. Mother and Stepfather have two children together and Stepfather

has adopted Mother’s oldest child.

{¶5} On August 13, 2024, Stepfather filed a petition for adoption of T.M.Z.

The petition included Mother’s consent to the adoption and asserted that Andrew’s

consent was not required because, among other things, he had failed without

justifiable cause to have contact with T.M.Z. for the previous one-year period.

{¶6} On January 6, 2025, the trial court held a hearing to determine whether

Andrew’s consent was required for the adoption. Following the hearing, the trial

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court issued a judgment entry finding that Andrew’s consent was not required

because he failed, without justifiable cause, to have contact with T.M.Z. for the one-

year period immediately preceding the filing of the petition.

{¶7} After determining that Andrew’s consent was not required, the trial

court held a hearing on January 21, 2025 to consider whether the adoption was in

T.M.Z.’s best interest. The trial court took the matter under advisement and, on

January 24, 2025, issued a judgment entry granting Stepfather’s adoption petition.

{¶8} On January 31, 2025, Andrew filed his notice of appeal, raising three

assignments of error for our review.

First Assignment of Error

The trial court’s finding that Appellant’s consent was not necessary was against the manifest weight of the evidence.

{¶9} In his first assignment of error, Andrew argues that the trial court erred

by determining that his consent was not required for the adoption. Specifically, he

argues that—even though he had no contact with T.M.Z. during the one-year period

prior to the filing of the adoption petition—he had justifiable cause because Mother

“secreted herself and [T.M.Z.].” (Appellant’s Brief at 10).

Standard of Review

{¶10} “[T]he right of a natural parent to the care and custody of his children

is one of the most precious and fundamental in law.” In re Adoption of Masa, 23

Ohio St.3d 163, 165 (1986). “Under most circumstances, both of a minor’s natural

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parents must provide written consent prior to the adoption of that minor.” In re

Adoption of S.S., 2017-Ohio-8956, ¶ 16 (3d Dist.). However, consent to an adoption

is not required of

[a] parent of a minor, 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 . . . for a period of at least one year immediately preceding either the filing of the adoption petition or the placement of the minor in the home of the petitioner.

R.C. 3107.07(A) (2015).1

{¶11} The application of R.C. 3107.07(A) involves “a two-step analysis.” In

re Adoption of M.B., 2012-Ohio-236, ¶ 23. First, the court must determine whether

the parent failed to provide more than de minimis contact with the child for the one-

year time period. In re Adoption of H.R., 2014-Ohio-5390, ¶ 25 (3d Dist.). Second,

“if a probate court finds the parent failed to provide more than de minimis contact

. . . , the court then determines ‘whether justifiable cause for the failure has been

proved by clear and convincing evidence.’” Id., quoting M.B. at ¶ 23.

{¶12} “Clear and convincing evidence is that measure or degree of proof . .

. which will produce in the mind of the trier of facts a firm belief or conviction as to

1 Effective March 21, 2025, R.C. 3107.07(A) was amended to state, in relevant part, that a court must find “by clear and convincing evidence that the parent has failed without justifiable cause to have more than de minimis contact with the minor” for the applicable one-year period before an adoption can proceed without that parent’s consent. (Emphasis added.) Specifically, the 2025 amendment replaced the word “provide” with “have” as it relates to the contact between the nonconsenting parent and the child during the relevant one-year period. This change does not affect the issues presented here.

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the facts sought to be established.” Cross v. Ledford, 161 Ohio St. 469 (1954),

paragraph three of the syllabus.

{¶13} “‘A probate court’s decision on whether justifiable cause exists will

not be disturbed on appeal unless the determination is against the manifest weight

of the evidence.’” H.R. at ¶ 25, quoting In re Adoption of K.C. 2014-Ohio-3985, ¶

23 (3d Dist.).

“In determining whether a judgment is against the manifest weight of the evidence, we must review the entire record, weigh the evidence and all reasonable inferences, consider witness credibility and determine whether, in resolving conflicts in the evidence, the trier of fact clearly lost its way and created such a manifest miscarriage of justice that there must be a reversal of the judgment and an order for a new trial.”

In re Adoption of C.N.A., 2018-Ohio-897, ¶ 9 (3d Dist.), quoting In re Adoption of

N.T.R., 2017-Ohio-265, ¶ 11 (10th Dist.).

Analysis

{¶14} In this case, Andrew acknowledges that he did not have contact with

T.M.Z. during the applicable one-year time period. On appeal, he argues that the

trial court erred by finding that his lack of contact was without justifiable cause.

Andrew contends that the greater weight of the evidence shows that there was

justifiable cause for his lack of contact since Mother “screen[ed] off [Andrew] from

his child.” (Appellant’s Brief at 10).

{¶15} The term “justifiable cause” is not defined in R.C. 3107.07(A). The

Ohio Supreme Court has “refused to adopt a ‘precise and inflexible meaning’ for

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‘justifiable cause,’ but instead has stated that ‘the better-reasoned approach would

be to leave to the probate court as finder of fact the question of whether or not

justifiable cause exists.’” In re Adoption of J.M.M., 2021-Ohio-775, ¶ 26 (3d Dist.),

quoting In re Adoption of Holcomb, 18 Ohio St.3d 361, 367 (1985). However,

justifiable cause can be established with evidence that there was “significant

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Related

In re Adoption of D.C.H.
2025 Ohio 5684 (Ohio Court of Appeals, 2025)

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Bluebook (online)
2025 Ohio 5000, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-adoption-of-tmz-ohioctapp-2025.