Manzanares v. Byington

Summary

The Utah Supreme Court reviewed whether an unmarried biological father's consent was required for the adoption of his child under Utah's Adoption Act. The court held that the birth mother's consent was valid despite alleged nondisclosure of related proceedings, but reversed the finding that the father knew or reasonably should have known of a qualifying circumstance. The case was remanded for determination of whether he complied with Colorado requirements and demonstrated a full commitment to his parental responsibilities.

Holdings

1. The birth mother's consent was valid because Utah law makes the consent effective when signed, and the judge's role is limited to certifying that the consent was understood and freely and voluntarily given. Vacatur of the judge's acceptance did not invalidate the consent.
2. For purposes of Utah Code section 78B-6-122(1)(c)(i)(A), knowledge is distinct from belief, suspicion, or unsupported speculation. A biological father must have accepted the qualifying circumstance as true on good grounds; mere suspicion that the mother might give birth or consent to adoption in Utah is insufficient.
3. On this record, Manzanares could not have known through reasonable diligence of Terry's concealed intent to give birth or consent to adoption in Utah because further inquiry would have been pointless in light of Terry's repeated denials.
4. Terry's six-day stay in Utah did not establish temporary residence under the statute. Her stated purpose was to visit her father, she had long been a Colorado resident, and the record lacked indicia of a settled abode or habitation in Utah.

Questions Presented

1. Whether the birth mother's adoption consent remained valid when the district court vacated the Utah judge's acceptance of the consent.
2. Whether Manzanares knew, or through reasonable diligence could have known, of a qualifying circumstance under Utah Code section 78B-6-122(1)(c)(i)(A) before the mother executed her consent.
3. Whether the mother's temporary presence in Utah constituted residence under the qualifying-circumstances provision.
4. What standards of appellate review apply to factual, legal, and mixed determinations under the Utah Adoption Act.

Disposition

reversed_and_remanded