In re Adoption of Y.E.F.
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The Supreme Court held that Ohio Rev. Code 2151.352 is unconstitutionally underinclusive as applied to indigent parents facing the loss of their parental rights in probate court and that indigent parents are entitled to counsel in adoption proceedings in probate court as a matter of equal protection of the law under the Fourteenth Amendment to the United States Constitution and Ohio Const. art. I, 2.
Petitioners filed petitions in the probate court to adopt Mother's two children. Mother filed a request for appointed counsel, which the probate court denied. The court of appeals affirmed the denial of Mother's request for appointed counsel, concluding that equal protection and due process guarantees are inapplicable to requests for appointed counsel in adoption causes brought by private petitioners. The Supreme Court reversed, holding that the disparate treatment between indigent parents faced with losing parental rights in a custody proceeding in juvenile court, who are entitled to appointed counsel, and indigent parents faced with losing parental rights in an adoption proceeding in probate court, who are not entitled to appointed counsel, violates equal protection guarantees.
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