In re Adoption of Baby Boy B.

Here, J.E.M. was required to present proof 11sof a significant custodial, personal, or financial relationship in order for his consent to be required pursuant to Arkansas Code Annotated § 9-9-206(a)(2) (Repl. 2009).1 Like the majority, it is my opinion that he did; however, because I reach my conclusion somewhat differently, I concur.

Custodial Relationship

In the case before us, the child at issue was in útero, and it is undisputed that J.E.M. did not have legal or physical custody of his child; thus, the relevant inquiry is whether J.E.M. had a significant custodial relationship with Baby Boy…