Amanda Marie Scudder v. Raylinia Ramsey

Summary

The court held that Amanda Scudder’s adult adoption terminated her biological mother’s derivative grandparent-visitation rights concerning P.S. It affirmed the civil-contempt finding because the evidence supported a finding that Scudder willfully denied scheduled visitation, but it reversed and remanded the attorney-fee award because fees for separate adoption litigation were improperly included. Justice Hart, concurring in part and dissenting in part, would have treated the adoption as a material change in circumstances requiring a best-interest determination rather than as automatically terminating visitation.