In re B.M.S., 949 N.E.2d 111

S.A.T. petitions to adopt his stepsons B.M.S. and J.C.S.; petition denied by the Franklin County Probate Court.
B.M.S. and J.C.S. are biological children of R.T. (wife) and M.S. (biological father, appellee).
R.T. and M.S. were previously married; divorce decree in Oklahoma (2002) granted custody to R.T. and ordered child support and visitation by M.S.
After the divorce, M.S. paid support until early 2005; he visited the children in Oklahoma roughly twice monthly through 2005.
In 2005, R.T. moved to Ohio with the children and married S.A.T.; M.S. stopped paying support.
In April 2006, S.A.T. filed for adoption; R.T. consented to the adoption.
In June 2006, an Oklahoma court reduced M.S.’s unpaid support to a judgment of $23,545.02 plus interest.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the best-interest determination supports adoption denial.	S.A.T. contends adoption is in the children’s best interest and should be granted.	Appellee argues continued relationship with him is the least detrimental alternative.	Not in the best interest; adoption denied.
Whether the probate court abused its discretion in weighing factors under RC 3107.161.	S.A.T. asserts the court undervalued positive parental influence and bonding.	Appellee argues the court properly weighed permanency and the father’s potential role.	No abuse of discretion; court balanced factors and concluded against adoption.

In re Adoption of Jordan, 72 Ohio App.3d 638 (1991) (adoption requires consent and best-interest analysis in two-step process)
In re Adoption I, 2007-Ohio-5966 (2007) (two-step process; consent excused and best-interest determination; standard of review)
In re Adoption of Ridenour, 61 Ohio St.3d 319 (1991) (abuse of discretion standard to review best-interest determinations)