In re Adoption of M.A.
In re Adoption of M.A., 2024 UT 6 (Pearce, A.C.J.)
Family Law/Statutory Interpretation
A woman petitioned the district court to examine her adoption records. The district court denied the petition concluding the woman had not shown good cause as required by statute. The Utah Supreme Court reversed and remanded, holding:
- The district court did not err in applying the good cause standard instead of the child’s best interest standard in denying the petition.
- The district court erred when it did not properly balance petitioner’s reasons for wanting access to her adoption records against her birth mother’s privacy interests—relying only on the legislature’s policy that adoptions should be sealed for 100 years.
- Practice tip: The good cause standard—not the child’s best interest—standard applies to petitions to unseal adoption records.
- Practice tip: In a footnote, the supreme court suggests that rule 107 of the Utah Rules of Civil Procedure may “smear some extra-textual gloss” on the statute. However, because the petitioner did not challenge the rule, the court left that question for another case.
- Judicial tip: An undefined good cause standard provides courts with discretion to consider the merits of individual cases.