Adoption of Gabe

The issue on appeal is whether a biological father (father) had a right to counsel in the adoption proceeding terminating his parental rights. The father appeals from decrees of the Probate and Family Court (probate court) approving the adoption of his two sons and severing his parental rights and duties. The petitioners are the children’s mother and stepfather. Throughout the proceeding in the probate court, the father did not retain counsel or receive appointed counsel.2 Four days after the entry of the decrees, the Supreme Judicial Court in Adoption of Meaghan, 461 Mass. 1006, 1007-1008…