Ohio Citizens Bank v. Mills

The issue presented for our consideration is whether R.C. 3107.15(A)(2), which in effect abrogated the common-law “stranger to the adoption” doctrine, may be applied in construing wills or trust documents created prior to the effective date of such statute. We answer such query in the negative, and accordingly reverse the court of appeals.

*155In determining whether or not an adopted child is included within a class designation in a will or trust instrument, and where a reading of the “four corners” of such instrument does not give a reviewing court the appropriate clues, various additional…