In the Matter of the Adoption of A.j.b.

Summary

The Oklahoma Supreme Court affirmed the trial court’s denial of an adoption without the natural father’s consent, holding the trial court did not abuse its discretion in finding insufficient clear‑and‑convincing evidence that the father failed to maintain a substantial relationship with the child. The Court reiterated that parental‑rights statutes are strictly construed and that clear‑and‑convincing proof is required even where the statute omits a “willful” requirement.