In re Adoption of W.M.J.

2025 Ohio 3166
Ohio Court of Appeals·Decided September 5, 2025·No. 30444·Published·Cited by 1 cases

Opinion

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.

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

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.

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

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 instances of abuse of discretion will result in decisions that are simply unreasonable, rather than decisions that are unconscionable or arbitrary.” AAAA Ents., Inc. v. River Place Community Urban Redevelopment Corp., 50 Ohio St.3d 157, 161 (1990). Decisions are unreasonable if they are not supported by a sound reasoning process. Id.

{¶ 13} When we consider evidentiary findings, we “must always be mindful of the presumption in favor of the finder of fact.” Eastley v. Volkman, 2012-Ohio-2179, ¶ 21. “The decision whether, and to what extent, to credit the testimony of particular witnesses is within the peculiar competence of the factfinder, who has seen and heard the witness.” State v. Lawson, 1997 WL 476684, *4 (2d Dist. Aug. 22, 1997).

B. Analysis of R.C. 3107.04

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

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