“Certainly, a parent who makes only one payment during the year—and thus is substantially in arrears on that year’s child support—has failed to provide support as required by law or judicial decree for a period of at least one year preceding the filing of the adoption petition.”

Justice DeWine, lead opinion

“The General Assembly, as

On January 25, the Supreme Court of Ohio handed down a unanimous decision, authored by Justice O’Donnell, in the case In re Adoption of M.B, 2012-Ohio-236.

The first part of the decision answers the question “do small monetary gifts paid directly to a child by an otherwise non-complying parent constitute maintenance and support so that