In re Adoption of W.M.J.

2025 Ohio 3166
CourtOhio Court of Appeals
DecidedSeptember 5, 2025
Docket30444
StatusPublished
Cited by1 cases

This text of 2025 Ohio 3166 (In re Adoption of W.M.J.) 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 W.M.J., 2025 Ohio 3166 (Ohio Ct. App. 2025).

Opinion

[Cite as In re Adoption of W.M.J., 2025-Ohio-3166.]

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

IN THE MATTER OF THE ADOPTION : OF W.M.J., A MINOR : C.A. No. 30444 : : Trial Court Case No. 2024 ADP 00084 : : (Appeal from Common Pleas Court- : Probate Division) : : FINAL JUDGMENT ENTRY & : OPINION

...........

Pursuant to the opinion of this court rendered on September 5, 2025, the judgments

of the trial court are 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,

ROBERT G. HANSEMAN, JUDGE

TUCKER, J., concurs and HUFFMAN, J., concurs in judgment only. -2- OPINION MONTGOMERY C.A. No. 30444

ARVIN S. MILLER, Attorney for Appellant KENT J. DEPOORTER, Attorney for Appellee

HANSEMAN, J.

{¶ 1} This case is before us on the appeal of the biological mother, V.J. (“Mother”),

from two judgments of the probate division of the Montgomery County Common Pleas Court

(“probate court”) concerning the adoption of her minor child, W.M.J. One judgment found

the probate court had jurisdiction over the adoption petition filed by A.J. (“Stepmother”); the

other determined that Mother’s consent to the adoption of W.M.J. was not needed.

According to Mother, the probate court lacked jurisdiction over the adoption proceeding

because neither Stepmother nor the biological father, J.J. (“Father”), physically lived in

Montgomery County, Ohio, when the adoption petition was filed.

{¶ 2} After reviewing the record and applicable law, we find no legal error or abuse of

discretion in the probate court’s exercise of jurisdiction over the adoption petition. The court

properly considered Stepmother’s status as a military spouse and her intention about her

legal residence. The court found the testimony of Stepmother and Father credible

concerning their intent to return to Montgomery County upon the conclusion of Father’s

military service. We defer to a trial court’s credibility determinations and find the court’s

decision was supported by sufficient evidence. Accordingly, the judgments of the probate

court are affirmed.

I. Facts and Course of Proceedings

{¶ 3} On July 11, 2024, Stepmother filed a petition with the probate court seeking to

adopt W.M.J., a minor child. The petition alleged that Father had full custody of W.M.J. and -3- had consented to the adoption. It further alleged that Mother’s consent was not required

because, for at least one year before the petition was filed, Mother had failed without

justifiable cause to have contact with W.M.J. or to provide maintenance or support for him.

The court scheduled a hearing on the adoption before a magistrate in October 2024 and

assigned an investigator. After Mother was served in July 2024, she did not file a written

objection to the adoption. However, she appeared at the October hearing and orally

objected.

{¶ 4} On October 29, 2024, the magistrate issued a decision finding that Mother was

lawfully served with notice but failed to file an objection within 14 days of service as required

by the Revised Code. The magistrate concluded that Mother’s consent to the adoption was

not required. Mother failed to object to the magistrate’s decision, and the trial court adopted

the decision on December 4, 2024. The court scheduled a non-contested trial on consent

and contested trial on the child’s best interests. Although the court issued a final appealable

order, Mother did not appeal.

{¶ 5} Counsel entered an appearance on Mother’s behalf and filed an objection to the

adoption contending that the probate court lacked jurisdiction to consider the petition. The

court set a hearing for April 1, 2025, to address Mother’s jurisdictional claim and whether

her consent to the adoption was necessary.

{¶ 6} The hearing took place as scheduled, and the court received testimony from

Stepmother and Father. Mother did not appear, although her counsel attended the hearing.

On April 4, 2025, the court entered its decision finding it had jurisdiction over the case and

that Mother’s consent to the adoption was not needed. Mother’s timely appeal from the

decision followed. -4- II. Jurisdiction

A. Introduction

{¶ 7} Mother’s assignment of error states:

The trial court errored [sic] when it determined it had jurisdiction over

the adoption of a child by his stepmother when the child, stepmother, and

father do not reside in Montgomery County, Ohio.

{¶ 8} Mother contends the trial court lacked jurisdiction because W.M.J., Stepmother,

and Father did not physically reside in Montgomery County, Ohio, as ostensibly required by

R.C. 3107.04. Mother further argues that even if we were to conclude that physical presence

had not been required based on Stepmother’s status as a military spouse, Father and

Stepmother failed to provide sufficient evidence that they were domiciled in Montgomery

County, “residing” there for the purposes of the statute. In response, Stepmother asserts the

trial court applied the correct legal standards in concluding it had jurisdiction. She notes

Mother made no effort to refute the evidence presented at the hearing.

{¶ 9} As a preliminary point, Mother’s notice of appeal indicates she is appealing from

two decisions: (1) the decision finding jurisdiction; and (2) the prior order adopting the

magistrate’s decision that Mother’s consent to adoption was not required. Mother’s brief,

however, addresses only the jurisdictional issue. As a result, we consider only that matter.

{¶ 10} In its decision on the jurisdictional question, the probate court considered the

testimony of Stepmother and Father and found they were credible. The court noted that

because Stepmother was married to Father, who was in the military, the jurisdictional

analysis differed from that applied to non-military members and spouses. Specifically, their

physical location was not the result of their own volition, and the residency analysis was a

question of intent. Based on the uncontroverted evidence, the court found that Stepmother -5- had met her burden of proving residency, and the court had jurisdiction over the adoption

petition.

{¶ 11} “A trial court's decision as to whether it has jurisdiction is a legal determination,

which is reviewed on appeal de novo; its weighing of the evidence as to a party's intent to

establish a domiciliary residence in the state is a factual question, which we review for an

abuse of discretion.” Freels v. Powers-Freels, 2015-Ohio-3915, ¶ 13 (2d Dist.). De novo

review is independent, and appellate courts do not defer to trial court decisions. Jackson v.

Internatl. Fiber, 2006-Ohio-5799, ¶ 17 (2d Dist.), citing State ex rel. AFSCME v. Taft, 2004-

Ohio-493, ¶ 27 (3d Dist.).

{¶ 12} Abuse of discretion “implies that the court's attitude is unreasonable, arbitrary

or unconscionable.” Blakemore v. Blakemore, 5 Ohio St.3d 217, 219 (1983). “[M]ost

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2025 Ohio 3166, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-adoption-of-wmj-ohioctapp-2025.