In re C.C.S., Case No. 2016-0395
Tenth District Court of Appeals (Franklin County)

ISSUES:
- When deciding whether a parent has voluntarily relinquished custody of a child, is it imperative that all steps be taken to ensure that the relinquishment was given without duress?
- Is there a fiduciary relationship between a parent placing a child for adoption and an adoption agency in which the agency has the duty to protect the parent?