In re J.G.

Citations

• 2020 Ohio 4701

Syllabus

Home study was not approved even though appropriate box on form was not checked narrative stated that adoption was not recommended. Probate court did not abuse its discretion in finding that agency's consent to adoption was not withheld unreasonably. Court erred when it told parties that hearing was on issue of consent only, yet considered best interests without permitting additional evidence. Court must independently consider best-interests factors even where agency's consent not unreasonably withheld.