Thomas L. Lagios, Appellant v. Kenneth Mitchell Goldman and Deanne Fields Goldman, Appellees

Summary

The court affirmed the adoption decree, holding that alleged defects in the adoption petition, expense affidavit, home-study filing, and notice did not deprive the circuit court of jurisdiction because the applicable requirements were either nonjurisdictional or substantially satisfied before entry of the decree. It further held that Lagios's consent was not required because he did not fall within any statutory category requiring a biological father's consent, that reopening the record to receive the home study was within the circuit court's broad discretion, and that the evidence supported the finding that the adoption was in the child's best interest. Justice Baker concurred to emphasize that Lagios had not raised a constitutional challenge and to address the notice issue, while Justice Hart dissented, asserting that strict statutory compliance and greater protection for the natural parent's rights were required.