## Facts

- Robert B. Joslyn married Michele A. Reynolds on July 1, 1994; Reynolds had three children from a prior marriage.
- On November 8, 1994, the probate court entered decrees by which Joslyn adopted each of Reynolds’s three children.
- Joslyn and Reynolds later divorced on August 14, 1998, and the divorce decree ordered Joslyn to pay child support for the three children.
- On July 30, 1999, Joslyn filed a probate-court action under R.C. 3107.16 seeking to vacate the adoption decrees for fraud and seeking compensatory damages, including repayment of child support he had paid.
- Joslyn alleged that Reynolds fraudulently induced him to marry her and adopt the children, claiming she married him so he would support her children and that her conduct toward him changed after the adoptions (including alleged extramarital affairs).
- Reynolds moved to dismiss under Civ.R. 12(B)(6), arguing the complaint was barred by the statutory time limit for challenging adoption decrees and otherwise failed to state a legally recognized claim.
- The probate court granted the motion to dismiss, and Joslyn appealed.

## Issues

1. Whether R.C. 3107.16(B) barred Joslyn’s fraud-based effort to vacate the adoption decrees because the action was filed more than one year after the decrees were entered.
2. Whether allegations that Joslyn discovered the alleged fraud later could extend or avoid R.C. 3107.16(B)’s one-year limit.
3. Whether Joslyn’s request for damages and reimbursement of child support was barred because it sought liability based on a promise of marriage or an obligation growing out of a contract to marry (R.C. 2305.29).
4. Whether the children’s interests and the finality of adoption supplied an additional basis to deny the requested relief.

## Decision

- The Ninth District Court of Appeals affirmed the probate court’s Civ.R. 12(B)(6) dismissal.
- The court held that R.C. 3107.16(B)’s one-year limitation barred Joslyn’s attempt to question the adoption decrees because the decrees were entered on November 8, 1994, and the complaint was filed on July 30, 1999.
- The court rejected efforts to avoid the statutory bar through later-discovered fraud allegations, treating the statutory time limit as controlling for post-decree attacks on adoptions.
- The court also agreed with the trial court that Joslyn’s damages theory effectively sought to impose liability tied to a promise of marriage or obligations arising from a marriage contract, which Ohio law abolishes under R.C. 2305.29.
- The court accepted the trial court’s reliance on the need for stability and permanence in adoption and the children’s welfare as consistent with denying relief in this posture.

## Legal Principles

- A Civ.R. 12(B)(6) dismissal is reviewed de novo; the court assumes well-pleaded factual allegations are true and asks whether the plaintiff can prove any set of facts entitling him to relief.
- R.C. 3107.16(B) imposes a strict one-year period after an adoption decree is entered during which the decree may be challenged; after that period, the decree generally cannot be questioned “by any person, in any manner, or upon any ground,” including fraud.
- Courts apply the adoption-challenge time limit as a firm bar to late-filed collateral attacks on finalized adoptions, reflecting the strong policy favoring permanence of adoptive parent-child relationships.
- R.C. 2305.29 abolishes certain causes of action based on marital promises and related conduct (including breach of contract to marry), and a party may not repackage such a theory as a fraud or reimbursement claim to obtain damages tied to the marriage relationship.
- Claims seeking to unwind adoptions and recoup child support years later conflict with the legal and practical need for stable parental status and ongoing support obligations established by adoption.

## Conclusion

The court affirmed dismissal because Joslyn’s complaint attacked finalized adoption decrees more than one year after entry, which R.C. 3107.16(B) bars, and because his damages and reimbursement theory depended on alleged marital inducements that Ohio law does not recognize as a basis for civil liability under R.C. 2305.29; the result also aligned with the law’s insistence on finality and stability in adoptive families.


Joslyn v. Reynolds, 2001 Ohio 1416 (2001)