M.T.O. v. A.O.

Citations

• 2026 Ohio 454

Syllabus

Subject-matter jurisdiction; R.C. 3109.051; R.C. 3107.15; visitation and companionship rights post-adoption; final appealable orders. Judgment vacated, in part, remanded in part and dismissed in part. Ohio's adoption statute R.C. 3101.15 divests a trial court of its subject-matter jurisdiction under R.C. 3109.051 to grant visitation rights to relatives of biological parents whose rights have been terminated by an adoption decree. Thus, the trial court lacked subject-matter jurisdiction to hear appellant's motion to intervene in the underlying action. Accordingly, the trial court's order dismissing appellant's motion to intervene is vacated and this matter is remanded to the trial court with instructions to dismiss appellant's motion to intervene for lack of subject-matter jurisdiction. Additionally, the trial court had no subject-matter jurisdiction to issue its order denying appellant's motion for relief from judgment and, therefore, this order is void. A void order is not a final appealable order. The appeal from this order is dismissed.