In re Adoption of K.A.H.
Ohio Court of Appeals
2015 Ohio 1971 (2015)
A stepfather, W.J.H., petitioned for adoption of his two stepchildren, K.A.C. and P.C.C., in an Ohio court. The children’s mother, S.H., was married to the children’s biological father, P.C., at the time the children were born. When S.H. and P.C. divorced, they agreed to a shared parenting plan in which P.C. would not pay child support, which was incorporated in the divorce decree. P.C. moved to the United Kingdom. In 2011, S.H. and W.J.H. were married. Between 2011 and 2013, P.C. did not see his children or pay for their support. P.C. did, however, make 91 minutes’ worth of long-distance phone calls, costing a total of approximately $174, to speak to his children, although he was not always successful in actually speaking to them. P.C. also sent his children cards and gifts. In 2013, W.J.H. filed his petition for adoption of the children, and P.C. filed a timely written objection. W.J.H. argued that P.C.’s consent to the adoption was not required under Ohio law, because P.C. did not provide more than de minimis contact with his children and did not support his children. The probate court held that P.C. did maintain more than de minimis contact with his children and therefore his consent was required. W.J.H. appealed.
Rule of Law
Holding and Reasoning (Tyack, J.)
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