In the Interest of R.D. R.D.
2016 Iowa Sup. LEXIS 30
| Iowa | 2016Background
- In 1965 R.D. was adopted in Iowa and the adoption records were sealed; her biological parents consented to the adoption and did not file any consent or affidavit regarding future disclosure.
- R.D., now 51, suffers from chronic depression, anxiety, and alcohol dependence; her treating clinicians opined that learning her biological parents’ identities is necessary for effective treatment and to prevent relapse and possible death.
- R.D. petitioned the juvenile court under Iowa Code § 600.16A(2)(d) to unseal her adoption file to obtain her biological parents’ names.
- The juvenile court found R.D. met the medical-evidence threshold in § 600.16A(2)(d) but denied disclosure because the statute mandates making every reasonable effort to prevent revealing biological parents’ identities to the adoptee; the adoption record contained no medical history aside from parent identities.
- The district court and this Court, after in camera review of the records, affirmed the denial, holding R.D.’s medical showing did not overcome the statutory protection of biological parents’ anonymity given the legislature’s emphasis on confidentiality.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether § 600.16A(2)(d) permits disclosure of biological parents’ identities where medical evidence shows disclosure is necessary to save life or prevent irreparable mental harm | R.D.: competent medical evidence shows knowing parents’ identities is necessary for treatment and to prevent relapse/death, so records should be opened | Biological parents’ anonymity and statutory confidentiality must be preserved; statute requires courts to prevent identity disclosure to adoptee and records contain no other medical info | Court: Although medical evidence satisfied the threshold to "may" open records, the statute’s mandatory command to prevent revealing parents’ identities controls; denial affirmed |
Key Cases Cited
- In re Adoption of S.J.D., 641 N.W.2d 794 (Iowa 2002) (adoption-records confidentiality and balance of interests)
- Head v. Colloton, 331 N.W.2d 870 (Iowa 1983) (constitutional privacy interest in avoiding disclosure of personal matters)
- In re Philip S., 881 A.2d 931 (R.I. 2005) (preserving confidentiality when balanced against adoptee interests)
- Bradey v. Child. Bureau of S.C., 274 S.E.2d 418 (S.C. 1981) (public interest in preserving adoption confidentiality)
- In re Adoption of Scott W.V., 124 A.3d 1181 (Md. Ct. Spec. App. 2015) (historical overview of sealing adoption records)