In re Adoption of M.A., 545 P.3d 241

Marianne Tyson, adopted in 1978, petitioned a Utah district court to unseal her adoption records to obtain health, genetic, or social information about her birth parents.
Tyson sought this information primarily for medical reasons, asserting her doctors needed family medical history regarding certain health issues.
The Utah Legislature requires adoption records to be sealed for 100 years, but allows courts to unseal them upon a showing of "good cause"; however, "good cause" is undefined in statute.
The district court denied Tyson’s petition, reasoning good cause required more than a general desire for health or genetic information and prioritized legislative privacy concerns.
Tyson appealed, challenging the district court’s statutory interpretation and the balancing of interests under Utah Rule of Civil Procedure 107(d).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the 'best interest of the child' or 'good cause' is the governing standard for unsealing adoption records	Tyson argued the best interest of the child standard should apply to her petition.	The court used the statutory 'good cause' standard instead.	The court held that the statutory good cause standard controls, not the best interest standard.
Definition of 'good cause' for unsealing adoption records	Tyson claimed lack of medical history is sufficient good cause.	District court required more than general desire for health/genetic info; needed a specific medical condition.	The Supreme Court found the district court’s interpretation too narrow, clarifying the statute allows for broader, case-by-case consideration of good cause.
Whether the district court properly balanced Tyson’s interests against privacy interests under Rule 107	Tyson argued her reasons for disclosure outweighed birth parent privacy after 40+ years.	District court focused solely on birth parent privacy and discounted Tyson’s reasons.	The Supreme Court held that courts must genuinely balance both parties' interests, not ignore the petitioner's grounds.
Constitutionality/equal protection concerns from denying access	Tyson briefly asserted a right to know her history under equal protection.	No response addressed; issue inadequately briefed.	The court declined to address constitutional claims due to insufficient briefing.

State v. Boyden, 441 P.3d 737 (Utah 2019) (clarifies standard for appellate review of district court discretion)
Scott v. Benson, 529 P.3d 319 (Utah 2023) (standard of review for statutory interpretation)
Reisbeck v. HCA Health Servs. of Utah, Inc., 2 P.3d 447 (Utah 2000) (scope of undefined 'good cause' standard)