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→‎Ohio: But Ohio has also established that fathers do have rights in frozen embryos, in ''Kotkowski-Paul v. Paul'', 2022-Ohio-4567, 204 N.E.3d 66 (Ct. App.).
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Many of the above decisions have been implicitly overruled by ''Dobbs''.
 
Many of the above decisions have been implicitly overruled by ''Dobbs''.
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But Ohio has also established that fathers do have rights in frozen embryos, in ''Kotkowski-Paul v. Paul'', 2022-Ohio-4567, 204 N.E.3d 66 (Ct. App.). "[T]he trial court did not err in concluding the subject embryos are marital property subject to allocation as part of the division of such property." ''Id.'' at  76.
    
== Tennessee ==
 
== Tennessee ==
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