S.A.S. v. K.H.B.
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The Supreme Court affirmed the judgment of the district court denying Father's motion to revoke his relinquishment of parental rights, holding that the district court correctly concluded that Father's relinquishment was voluntary, and any failure to notify Father of his statutory right to receive counseling did not invalidate the relinquishment.
Father consented to the adoption of his biological daughter and signed a relinquishment of parental rights. Later, Father filed a motion to revoke his relinquishment, alleging that his relinquishment was involuntary. The district court denied the motion. The Supreme Court affirmed, holding (1) Father failed to identify an evidentiary basis for his allegation that his relinquishment was involuntary; (2) Father did not have a due process right to have his relinquishment invalidated by the adoptive parents' failure to notify him of his statutory right receive counseling; and (3) Father lacked standing to assert an equal protection challenge to the relinquishment requirements that apply to biological fathers.
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