In re Adoption of R.A.H.

Citations

• 2021 Ohio 1667

Syllabus

The trial court ruled that a domestic violence civil protection order prohibiting appellee from having contact with his child provided justifiable cause for appellee's failure to have contact with the child in the one-year period before appellant filed a petition seeking to adopt the child. Based upon this conclusion, the court found that appellee's consent to the adoption was required. The protection order, though a relevant consideration, did not necessarily require a finding that appellee had justifiable cause for his failure to have contact with the child during the relevant time period. Judgment reversed and remanded.