In re Adoption of Kessler

As stated by this court in In re Adoption of Kessler (1993), 87 Ohio App.3d 317, 322, 622 N.E.2d 354, "Ohio Courts and this court have repeatedly held that any contribution toward child support, no matter how meager, satisfies the maintenance and support requirements of R.C. 3107.07(A)." In Kessler, as in the case before us now, it was uncontested that the Child Support Enforcement Agency had received only one payment from the obligor parent in the year preceding the filing of the petition to adopt, and that payment was the result of a federal income tax refund intercept. Id. The Court held in Kessler that the payment constituted support and that the father's consent was required. Kessler at 323.