SMB&P represented a grandmother seeking to adopt her granddaughter without the consent of the child’s biological mother. SMB&P successfully argued that the mother’s consent to the adoption was not required due to the mother’s failure, after notice and a hearing, and without justifiable cause, to have more than de minimus contact with the child in the year preceding the adoption. A copy of the Twelfth District Court of Appeals’ opinion affirming the decision of the Warren County Probate Court can be viewed here: https://www.supremecourt.ohio.gov/rod/docs/pdf/12/2019/2019-Ohio-3055.pdf