Manzanares v. Byington, 270 P.3d 486

Manzanares challenged a district court order terminating his parental rights after the court found his consent to Baby B’s adoption not required; the district court vacated the Utah judge’s acceptance of Terry’s consent based on alleged deception but treated Terry’s consent as valid.
Terry gave birth in Utah to Baby B. after planning to place the child for adoption; the birth occurred February 17, 2008, with Byingtons filing a Utah adoption petition on February 19, 2008.
Manzanares filed a Colorado paternity action in early 2008 alleging Terry planned to relocate to Utah to place the child for adoption and sought to preserve his rights; he later argued he did not know of qualifying circumstances before Terry signed consent.
The Utah Adoption Act requires unmarried biological fathers to act to preserve rights: (i) file a Utah paternity action before the mother executes consent, and (ii) comply with further duties or risk losing rights, with limited exceptions.
The majority held Terry’s consent was valid and that Manzanares did not prove he knew or should have known of qualifying circumstances; it remanded for consideration of Colorado compliance and paternal responsibility, and reversed the district court’s finding on knowledge under the Act.
The dissent would have applied an inquiry-notice standard consistent with O’Dea v. Olea and rejected the majority’s knowledge-centric approach, arguing it undermined finality and the legislature’s intent.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Terry’s Utah consent was valid.	Manzanares challenged validity of consent due to district court vacatur.	Terry freely and voluntarily consented; consent was valid despite vacatur.	Terry’s consent valid; vacatur had no legal effect on validity.
Whether Manzanares knew or could have known of qualifying circumstances before Terry’s consent.	Manzanares did not know of qualifying circumstances; he acted on fears and beliefs.	Manzanares knew or should have known, based on his Colorado filings and circumstances.	No basis in record to find knowledge; remand limited to Colorado and parental-responsibility determinations.
What standard governs knowledge of qualifying circumstances under the Adoption Act?	Adoption Act requires knowledge or should have known (inquiry notice) rather than mere belief.	Majority adopts a more stringent or different standard.	Standard clarified as knowledge or should have known, not merely belief; majority’s approach rejected.
Does residence in Utah constitute a qualifying circumstance here?	Residence in Utah could qualify as a circumstance.	Terry did not reside in Utah; thus not a qualifying circumstance.	Residence in Utah not established; not a qualifying circumstance in this record.

O'Dea v. Olea, 217 P.3d 704 (2009 UT 46) (establishes inquiry-notice standard for knowledge of qualifying circumstances)
Parker v. Irizarry, 945 P.2d 676 (Utah 1997) (standard for reviewing findings of fact in Utah courts)
Osborne v. Adoption Ctr. of Choice, 70 P.3d 58 (Utah 2003 UT 15) (case addressing mother’s communications to father about adoption)
In re L.K., J.S. v. P.K. (In re L.K.), 220 P.3d 464 (Utah 2009 UT 70) (discusses notice and knowledge in adoption context)