In re Adoption of C.A.H. v. R.S.E.
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The Supreme Court reversed the trial court's finding that Father's consent to the adoption of his child was irrevocably implied in this contested adoption proceeding, holding that a parent's implied consent to the adoption of a child may not be based solely on the parent's failure to appear at a single hearing.
Grandparents filed a petition to adopt Child, claiming that Father's consent to the adoption was unnecessary. Father contested the adoption. But when Father failed to appear the morning of the final hearing in the adoption case, the trial court entered a decree of adoption, finding that Father's consent was not necessary. The Supreme Court reversed, holding that where Father appeared at the initial final hearing before it was rescheduled, responded to pleadings, and maintained communication with his attorney throughout the proceedings, the trial court erred in finding that Father's consent was irrevocably implied because of his failure to attend the final hearing.
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