In re Adoption of T.U.

Citations

• 2020 Ohio 841

Syllabus

Trial court erred in finding that natural father's consent to adoption was not required based on father's failure to support the child because father complied with zero-dollar support order, but the error was harmless. Father's consent was not required because his voluntary agreement to have no contact with the child in exchange for paying no child support was not sufficient justification for having no more than de minimis contact with the child in the year prior to the filing of the adoption petition.