In Re Baby E.Z.
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Baby E.Z., the child of John Wyatt and the birth mother, who were never married, was born in Virginia. After the birth, the birth mother consented to an adoption, after which Wyatt initiated custody and visitation proceedings in a Virginia court. The prospective parents then filed a petition for adoption in Utah district court. Wyatt filed a motion in the Utah court contesting the adoption and requesting permission to intervene. The Utah court denied Wyatt's motion, holding that he had waived his rights to the child, that he could not intervene, and that his consent to the adoption was not required. Subsequently, the Virginia court issued an order granting Wyatt custody of the baby. On appeal, Wyatt argued that the federal Parental Kidnapping Prevention Act (PKPA) deprived the Utah district court of jurisdiction over the adoption proceeding and required enforcement of the Virginia court order awarding him custody of the baby. The Supreme Court affirmed the district court's denial of Wyatt's motion, holding (1) the PKPA applied to the adoption proceedings, but that Wyatt waived any claim under the PKPA by failing to raise the statute below; and (2) Wyatt failed to timely assert his parental rights under Utah law.
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