In Re Adoption of Searle

PARKER, Judge.

Respondent’s first contention on this appeal is that the trial court erred in denying his motions for directed verdict and for judgment n.o.v. because the evidence, when considered in the light most favorable to petitioner, failed to establish a willful abandonment. We disagree.

Prior to 1 October 1985, two procedures were available to enable a petitioning party to adopt a minor child without the con sent of the opposing biological parent. First, under G.S. 7A-289.32, a court could terminate the parental rights of a biological parent upon a finding of one of the grounds…