In re Adoption of K.R.S.
In re Adoption of K.R.S., 2024 UT App 165 (Harris, J.)
Parental Rights/Adoption
The district court terminated a father’s parental rights during the pendency of the adoption of the child by the stepfather. The termination order did not resolve the underlying adoption. The father appealed. The Utah Court of Appeals dismissed the appeal, holding:
- The court lacked jurisdiction. Parental termination orders are not immediately appealable as of right when a district court enters the order in the context of an adoption proceeding.
- Practice tip: While the court did not create an exception to the final judgment rule, parties can still seek rule 54(b) certification to appeal the order. Courts are “encouraged” to carefully consider such requests.