R.C.S. v. A.O.L., 291 P.3d 215

Shaud challenges district court ruling that he waived rights under the Utah Adoption Act for failure to strictly comply with notice filing.
Act requires unwed fathers to file notice of paternity with Vital Records, which is deemed filed when entered into the registry.
Vital Records allegedly delayed entry due to negligence, resulting after the birth mother's consent to adoption.
Birth mother consented to adoption before Shaud’s notice was entered, prompting petition to determine parental rights.
District court granted Act of Love’s motion in limine, excluding evidence of Vital Records’ negligence and denying Shaud’s rights.
Court reverses and remands to evaluate whether Vital Records received notice before consent; holds act as applied may violate due process.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Due process standard for filing under Act	Shaud argues agency negligence violated due process	Shaud’s notice failure is due to his own inaction or strict compliance	Remand for due-process analysis; reject district court's narrow reading
Meaningful opportunity to protect rights	Act should provide meaningful chance to develop relationship	Strict compliance balances interests and ensures prompt adoptions	Statute applied unconstitutionally as to Shaud; requirement adjusted on remand
Preservation of constitutional challenge	Due process raised in district court	No explicit constitutional challenge preserved	Majority finds preserved; dissent rejects preservation under current record

In re Adoption of T.B., 2010 UT 42 (Utah 2010) (due process requires meaningful procedures to protect paternal rights)
Sanchez v. L.D.S. Servs., 680 P.2d 753 (Utah 1984) (strict compliance upheld; lack of timely filing risks rights)
Thurnwald v. A.E., 163 P.3d 623 (Utah 2007) (strict compliance may violate due process when agency action outside father's control)