In Re the Adoption of E.B.F., J.W., Appellant (Respondent Below) v. D.F., Appellee (Petitioner Below)

Summary

The Indiana Supreme Court held that the mother’s consent was required to grant the stepmother’s adoption petition because the mother had justifiable cause for her lack of communication and the father and stepmother thwarted her attempts to communicate. The Court reversed the trial court’s consent determination and remanded for further proceedings. Justice Slaughter dissented, arguing the trial court’s findings were correct and that the majority’s new justification was unwarranted.