Under Ohio law, incarcerated parents who have actively sought to maintain a connection with their children cannot lose their children to adoption without their consent. Where a parent satisfies this standard, may the State, consistent with the Fourteenth Amendment's Due Process Clause, entirely disregard his efforts to maintain his paternal ties and dispense with his statutory right to consent to the adoption of his children exclusively on the basis of the crime for which he was imprisoned, and in the absence of any statutory basis treating his crime as dispositive?

Whether incarcerated parents have a due-process right to consent to adoption of their children under the Fourteenth Amendment