Manzanares v. Byington
308 P.3d 382
| Utah | 2012Background
- Manzanares challenged the district court’s order terminating his parental rights in Baby B.
- District court found Terry’s Utah consent to adoption was not invalid and that Manzanares knew or should have known of qualifying circumstances.
- Court reversed, clarifying Adoption Act standards and rejecting the “actual knowledge” touching on qualifying circumstances.
- Terry gave birth in Utah; Byingtons sought Utah adoption; Manzanares filed Colorado paternity action to protect rights.
- Colorado and Utah proceedings overlapped; district court vacated Judge Hilder’s acceptance of Terry’s Utah consent but treated the consent as valid for purposes of Utah law.
- Court remanded to address Manzanares’s compliance with Colorado procedures and his demonstrated commitment to parental responsibilities while keeping Terry’s consent valid.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Terry’s Utah consent was valid under the Adoption Act | Manzanares contends consent was invalid due to district court vacatur and lack of strict compliance. | Byingtons argue consent was valid; district court found deception but not invalidating of consent. | Terry’s consent was valid. |
| Whether Manzanares knew or should have known of qualifying circumstances | Manzanares did not know, and could not have known via reasonable diligence, of Utah-based qualifying circumstances before consent. | Court found he knew or should have known via Colorado filings. | No basis for finding knowledge before consent; remand for Colorado compliance and parental commitment. |
| What standard governs knowledge of qualifying circumstances | Inferences from known facts can show knowledge. | Knowledge requires objective inquiry notice or actual knowledge. | Adoption Act requires knowledge or reasonable diligence should have known; rejected pure belief standard. |
| Effect of vacatur of Judge Hilder’s acceptance on validity | Vacatur could affect validity of consent. | Vacatur had no legal effect on validity of consent itself. | Vacatur of acceptance did not undermine validity of consent. |
Key Cases Cited
- O'Dea v. Olea, 2009 UT 46, 217 P.3d 704 (Utah 2009) (establishes inquiry notice standard for knowledge of qualifying circumstances; strict compliance required.)
- Parker v. Irizarry, 945 P.2d 676 (Utah 1997) (standard for clearly erroneous factual findings; de novo review of law.)
- In re I.K. (J.S. v. P.K.), 2009 UT 70, 220 P.3d 464 (Utah 2009) (discusses mother’s communications and knowledge concepts in adoption context.)