Adoption of Child by Non-Relative Legal Custodian Is Not Exempt from Pre-Adoption Placement Requirements

The Supreme Court of Ohio ruled today that the preadoption placement procedures for “private” adoptions set forth in R.C. 5103.16(D) must be followed even in cases where the child has been living with the prospective adoptive parents pursuant to an award of legal custody by a juvenile court. The Court’s 6-0 decision was authored by Justice Evelyn Lundberg Stratton.