The Appellate Group

In re Adoption of R.P. & S.P.

In re Adoption of R.P. & S.P., 2026 UT 9 (Hagen, J.)

Adoption

The Utah Supreme Court held:

(1) The district court did not err when it interpreted the plain language of the Adoption Act’s intervention provision to bar Paternal Grandmother from maintaining her adoption petition because she failed to intervene in Maternal Grandmother’s adoption proceeding. 
(2) The district court applied the intervention provision correctly because barring a guardian and first-in-time petition filer from maintaining her adoption petition for failing to intervene, while harsh, is not an overwhelmingly absurd result from applying the intervention provision.

Judicial tip:

The Court of Appeals erred in its absurdity doctrine analysis because its analysis was not based on the actual result that the district court reach by applying the intervention provision, but rather, it was based on a hypothetical circumstance.

Read the full court opinion