In Re the Adoption of a Male Minor Child

OPINION OF THE COURT BY

BURNS, J.

The child’s natural mother appeals from the lower court’s denial of her request to set aside the adoption decree on the grounds that the natural mother’s consent was obtained by means of fraud, duress and undue influence.

The natural mother contends that the lower court erred:

1. When it held that her written consent was valid notwithstanding noncompliance with Hawaii Revised Statutes (HRS) § 578-1 and Hawaii Family Court Rules (HFCR), rule 103(f)(5).

2. When it found that she failed to prove her allegations of fraud.

3. When it refused to allow her friend to…