In re A.J.W.

Citations

• 2024 Ohio 3124

Syllabus

The trial court did not err in finding that Father's consent to the adoption of his minor child was not required petitioners established by clear and convincing evidence that Father had failed, without justifiable cause, to have more than de minimis contact with the child in the year preceding the filing of the petition for adoption. The probate court did not abuse its discretion in denying Father's oral request for a continuance on the day of the consent hearing. Father failed to establish ineffective assistance of trial counsel. Judgment affirmed.