Kramer v. Catholic Charities of the Diocese of Fort Wayne-South Bend, Inc.
Annotate this CaseJason and Justina Kramer hired Catholic Charities to facilitate the adoption of E. After M.S. gave birth to E., the Kramers took E. home with them. The Kramers subsequently learned that R.M. had registered as the putative father of E. The Kramers nonetheless petitioned to adopt E., and R.M. contested the adoption. R.M. received full custody of E. after E. had been in the Kramers’ custody for eight months. The Kramers brought a negligence action against Catholic Charities, alleging that Catholic Charities should have checked the putative father registry prior to placing E. with them, or, alternatively, that Catholic Charities had a duty to disclose its failure to conduct a pre-placement check of the registry. The trial court granted summary judgment for Catholic Charities. The Supreme Court affirmed, holding (1) the applicable Indiana statute does not impose the requirement of a pre-placement registry check; and (2) the Kramers failed to demonstrate that Catholic Charities had any duties with respect to the putative father registry in excess of its statutory obligations.
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