From In the Matter of L.D.R.S., decided last month by the Ohio Court of Appeals (Judge Matt Lynch, joined by Judges John Eklund and Robert Patton), but just noted last week in the Westlaw Bulletin:
L.D.R.S. was born on August 20, 2014, to unmarried parents.
On September 5, 2019, the juvenile court awarded John Snyder, the child's natural father and appellee, legal custody. At the same time, Zadunajsky, L.D.R.S.'s paternal grandmother, was granted companionship rights with the child {pursuant to R.C. 3109.12(A), which provides that "[i]f a child is born to an unmarried woman … the parents of the father … may file a complaint requesting that the court grant them reasonable companionship or visitation rights with the child."}
On December 20, 2021, Snyder filed a Motion for Termination or Modification of Visitation on the grounds that "the child has now been adopted [by his stepmother] and there [is] an intact family."
The lower court agreed that the stepmother's adopting the child cut off the grandmother's visitation rights under Ohio Rev. Code 3107.15(A)(1)(a), which provides:
