In re Adoption of D.C.H.

Citations

• 2025 Ohio 5684

Syllabus

Adoption; R.C. 3107.07(A); Best Interest; R.C. 3107.161(C); Burden of Proof; Due Process. Due process requires that a natural parent has adequate notice and a meaningful opportunity to be heard before parental rights are terminated through an adoption proceeding. Due process is a flexible concept and must meet the demands of a particular situation. Parental consent is generally required for an adoption to proceed. However, R.C. 3107.07(A) states that the consent of a natural parent is not required if a parent has failed to provide maintenance and support to the child or has failed to have more than de minimis contact with the child in the year preceding the adoption petition without justifiable cause. During the best interest phase of an adoption proceeding, the petitioners retain the burden of proof.