In re Adoption of R.P..., 2026 UT 9

Background

After the children’s parents died, their grandmothers were appointed co-guardians and Paternal Grandparents later filed the first adoption petition. 1
Maternal Grandparents filed a competing adoption petition and served Paternal Grandmother with statutory notice warning she had to intervene within 30 days. 2
Paternal Grandmother did not intervene in Maternal Grandparents’ proceeding despite receiving notice twice. 3
Maternal Grandmother moved for summary judgment to bar Paternal Grandmother’s adoption petition, and the district court barred both Paternal Grandparents. 4
The court of appeals agreed the statute barred Paternal Grandmother, but reversed on absurdity grounds based on a supposed disparity between her and Paternal Grandfather. 5
The Utah Supreme Court reversed, holding the intervention provision barred Paternal Grandmother and no absurd result justified departing from the statute. 6

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does the intervention provision bar Paternal Grandmother’s adoption petition? 7	Paternal Grandmother says the competing-petitions provision governs.	Maternal Grandparents say notice plus failure to intervene bars her petition.	Yes; she was required to intervene and is barred. 8
Did the court of appeals properly apply the absurdity doctrine? 9	Paternal Grandmother says barring her while allowing her spouse would be absurd.	Maternal Grandparents say the court relied on a hypothetical, not the actual ruling.	No; its absurdity analysis was based on a false premise. 10
Is barring a first-in-time guardian petitioner for failing to intervene absurd? 11	Paternal Grandmother says it removes an ideal adoptive home from consideration.	Maternal Grandparents say the statute rationally requires intervention in competing proceedings.	No; the result is harsh but not overwhelmingly absurd. 12

Key Cases Cited

Prinsburg State Bank v. Abundo, 296 P.3d 709 (Utah 2012) (certiorari review applies the same standard used by the court of appeals 13)
Pinney v. Carrera, 469 P.3d 970 (Utah 2020) (the supreme court gives no deference to the court of appeals’ decision 14)
Bearden v. Croft, 31 P.3d 537 (Utah 2001) (statutory interpretation questions are reviewed for correctness 15)
Penunuri v. Sundance Partners, Ltd., 301 P.3d 984 (Utah 2013) (statutory interpretation seeks legislative intent from plain language 16)
Anderson v. Utah Dep't of Com., 572 P.3d 373 (Utah 2025) (statutes are read as a whole, not in isolation 17)
Hertzske v. Snyder, 390 P.3d 307 (Utah 2017) (statutory provisions are construed in context of the entire scheme 18)
Mind & Motion Utah Invs., LLC v. Celtic Bank Corp., 367 P.3d 994 (Utah 2016) (shall creates mandatory statutory obligations 19)
Graves v. N.E. Servs., Inc., 345 P.3d 619 (Utah 2015) (the word any has broad, encompassing import 20)
In re Adoption of M.A., 545 P.3d 241 (Utah 2024) (specific statutory provisions control over general ones when inconsistent 21)
Arnold v. Dep't of Workforce Servs., 491 P.3d 957 (Utah 2021) (the absurdity doctrine applies only when plain meaning yields an absurd result 22)
Bagley v. Bagley, 387 P.3d 1000 (Utah 2016) (absurdity doctrine requires an exacting showing 23)
Scott v. Benson, 529 P.3d 319 (Utah 2023) (hypothetical absurd results do not justify departing from statutory text 24)
State v. Sanders, 445 P.3d 453 (Utah 2019) (absurdity arguments based on hypothetical circumstances fail 25)
In re E.H., 137 P.3d 809 (Utah 2006) (intervention is the means by which an outsider becomes a party 26)
Utley v. Mill Man Steel, Inc., 357 P.3d 992 (Utah 2015) (unambiguous statutory text usually controls even if harsh or impractical 27)