Washington Law Review


In In re Dependency of G.C.B., a Washington court of appeals held that an individual whose parental relationship was involuntarily terminated under the dependency statute lacks standing to later petition to adopt that same child. This Note argues that the Washington adoption statute would not necessarily prevent an equivocating parent who voluntarily relinquished her child from attempting to undo the finality of termination by later seeking to adopt. Nor does the statute effectively limit who can petition to adopt a child to individuals who have been chosen by the child's custodian or who have had the child placed with them. The Note proposes that the Washington adoption statute should be amended to ensure that parents whose relationship with a child is terminated cannot later attempt to relitigate that issue through adoption, and further proposes that eligibility to petition to adopt should be limited so that the child's best interests, not the desires of competing adults, are served.

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