In re Adoption of A.C.B.Annotate this Case
The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the probate court finding that a single payment of child support made by Father did not amount to the provision of support "as required by law or judicial decree" and therefore concluding that Father's consent was not required for the adoption of his child, holding that the single payment was insufficient to preserve Father's right to object to the adoption of his child.
Father was a biological parent of the child who was ordered by a court to pay child support of $85 per week. The only payment Father made in the year before the filing of the adoption petition was a single payment of $200, constituting less than five percent of his annual obligation. On appeal, Father asserted that under Ohio Rev. Code 3107.07(A), provision of any amount of maintenance and support during the statutory one-year period constituted maintenance and support "as required by law or judicial decree." The Supreme Court disagreed, holding that, under the plain language of the statute, Father did not provide for the maintenance and support of the child "as required by law or judicial decree" for the requisite one-year period.