In re E.G.C.

Citations

• 2021 Ohio 276

Syllabus

Probate court erred in finding that Father's consent was not necessary, as the court failed to issue a decision that reflects consideration of the issue of justifiable cause for Father's failure to communicate. Though it is undisputed that Father's contact with the child was de minimis, the court did not address the second element of the necessary analysis that the failure to do so was without \justifiable cause.\