Ex parte O.S. and J.A.S. (In re O.S. and J.A.S. v. E.S.)

Summary

The Court held that the circuit court lacked subject-matter jurisdiction to hear an independent action challenging a probate court's adoption judgment, including a challenge based on fraud. Because the adoption statutes provide a remedy in the probate court and vest that court with jurisdiction over adoption proceedings, the circuit court's general equitable jurisdiction did not extend to the challenge. The Court reversed and remanded the Court of Civil Appeals' judgment. Justice Murdock, dissenting, would have held that the circuit court had jurisdiction to determine whether the probate judgment was void.