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Patterson v. Robbins

Supreme Court of Arkansas
May 16, 1988
749 S.W.2d 330 (Ark. 1988)

Summary

In Patterson, the supreme court held that section 9-9-204, which confers standing to adopt, did not exclude persons who had served as foster parents of the minor to be adopted.

Summary of this case from Schubert v. Arkansas Dep't of Human Services

Opinion

No. 88-108

Opinion delivered May 16, 1988

1. ADOPTION — STANDING TO ADOPT — FOSTER PARENTS. — Although Ark. Code Ann. 9-9-210(a)(3) (1987) provides that a petition for adoption shall state "the date the petitioner acquired custody of the minor and of placement of the minor and the name of the person placing the minor; and a statement as to how petitioner acquired custody of the minor," the appellate court did not interpret the language having to do with the contents of the petition as meaning that a person who does not have custody and with whom the child has not been "placed" has no standing; standing to adopt is conferred by Ark. Code Ann. 9-9-204 (1987), and that statute does not exclude persons who have served as foster parents of the minor to be adopted. 2. COURTS — JURISDICTION — PROBATE COURT HAS AUTHORITY TO DECIDE ISSUE. — Ark. Code Ann. 9-9-207 (1987) gives the probate court authority to decide whether the Department of Human Services, as legal guardian of the minor, has unreasonably withheld its consent to adopt. 3. PROHIBITION — COURT HAD AUTHORITY TO DECIDE ISSUE RAISED — WRIT DENIED. — Where the probate court had the authority to decide the issue raised, the writ of prohibition was denied.

Petition for Writ of Prohibition; denied.

Claudia Driver, Asst. General Counsel, for appellant Dep't of Human Services; and Robert Depper, for appellants Robert E. Smith and Verdia Smith.

No response.


The petitioners contend that the Probate Court of Garland County lacks jurisdiction of an adoption petition because the persons seeking to adopt are foster parents who lack standing. Although the petitioners are correct in noting that Ark. Code Ann. 9-9-210(a)(3) (1987) provides that a petition for adoption shall state "the date the petitioner acquired custody of the minor and of placement of the minor and the name of the person placing the minor; and a statement as to how petitioner acquired custody of the minor," we do not interpret that language having to do with the contents of the petition as meaning that a person who does not have custody and with whom the child has not been "placed" has no standing. Standing to adopt is conferred by Ark. Code Ann. 9-9-204 (1987), and that statute does not exclude persons who have served as foster parents of the minor to be adopted.

[2, 3] In addition, Ark. Code Ann. 9-9-207 (1987) gives the probate court authority to decide the issue raised by the foster parents whether the Department of Human Services, as legal guardian of the minor, has unreasonably withheld its consent to adopt. The foster parents' rights in that respect are not subject exclusively to the department's policies, the Arkansas Administrative Procedure Act, Ark. Code Ann. 25-15-201 through 25-15-214 (1987), and circuit court review.

Petition for writ of prohibition denied.


Summaries of

Patterson v. Robbins

Supreme Court of Arkansas
May 16, 1988
749 S.W.2d 330 (Ark. 1988)

In Patterson, the supreme court held that section 9-9-204, which confers standing to adopt, did not exclude persons who had served as foster parents of the minor to be adopted.

Summary of this case from Schubert v. Arkansas Dep't of Human Services
Case details for

Patterson v. Robbins

Case Details

Full title:Walt PATTERSON, et al. v. Hon. John B. ROBBINS

Court:Supreme Court of Arkansas

Date published: May 16, 1988

Citations

749 S.W.2d 330 (Ark. 1988)
749 S.W.2d 330

Citing Cases

Schubert v. Arkansas Dep't of Human Services

[T]he Court finds that the Juvenile division has exclusive jurisdiction regarding the adoption of the…

Opinion No. 2007-292

This provision of the act confers standing to adopt. See Patterson v. Robbins, 295 Ark. 511, 749 S.W.2d 330…