In re L.R.O.

Citations

• 2020 Ohio 3200

Syllabus

In this adoption action, appellants (maternal grandparents) appeal the probate court's determination that biological mother's consent to the adoption of her two children was necessary. The probate court's determination that Mother had justifiable cause for de minimis contact with the children was supported by clear and convincing evidence. But, based upon In re Adoption of A.C.B., Ohio Slip Opinion No. 2020-Ohio-629, ___ N.E.3d ___, which was decided after the probate court's decision, the probate court erred in concluding Mother had met the R.C. 3107.07(A) support requirement. Thus, the case must be remanded for a determination of whether Mother was justified in failing to support the children. Judgment reversed and remanded.