In Re Adoption of H.N.R., 47 N.E.3d 803

C.S.M. challenges Ohio's Putative Father Registry deadline of 30 days after birth for registering as a putative father, arguing it is unconstitutional as applied when a child is relinquished for adoption after 30 days.
H.N.R. was born August 29, 2013 in West Virginia; no father listed on the birth certificate; DNA testing indicated a 99.99% probability that C.S.M. is the biological father.
The mother surrendered H.N.R. for adoption in January 2014; Ohio searched the OPFR and found no registered putative father related to H.N.R. or the mother.
Adoption proceedings were filed by prospective adoptive parents in Greene County on February 11, 2014; C.S.M. filed custody complaints and moved to intervene in April 2014.
The probate court denied C.S.M.’s requests and allowed the adoption to proceed without his participation; the Second District affirmed, and C.S.M. appealed to the Ohio Supreme Court.
The majority held that the challenge is as-applied, requiring prejudice to the specific claimant; C.S.M. did not allege awareness or action to preserve rights before the adoption petition, so the court rejected the due-process challenge as applied.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the 30-day OPFR deadline is unconstitutional as applied	C.S.M. argues the deadline arbitrarily deprives him of notice and involvement.	The state has a legitimate interest in expediting adoptions and protecting children's best interests; the as-applied challenge lacks prejudice.	No prejudicial injury shown; as-applied challenge fails

Lehr v. Robertson, 463 U.S. 248 (U.S. 1983) (private interest in opportunity to develop a relationship protected when father fully participates)
Caban v. Mohammed, 441 U.S. 380 (U.S. 1979) (biological link alone does not guarantee constitutional protection without established relationship)
Mathews v. Eldridge, 424 U.S. 319 (U.S. 1976) (three-factor test for procedural due process)
In re Adoption of Zschach, 75 Ohio St.3d 648 (Ohio 1996) (balancing private and state interests in adoption context)
In re Adoption of P.A.C., 126 Ohio St.3d 236 (Ohio 2010) (context on timing and notice considerations in adoptions)
Palazzi v. Estate of Gardner, 32 Ohio St.3d 169 (Ohio 1987) (prejudice required for as-applied constitutional challenges)
Sacramento County v. Lewis, 523 U.S. 833 (U.S. 1998) (arbitrary laws and due-process concerns)
Norwood v. Horney, 110 Ohio St.3d 353 (Ohio 2006) (due-process requires meaningful standards in laws)