In Re the Adoption of Hannah L.

OPINION

WINFREE, Justice.

I. INTRODUCTION

Alleging that parenting failures waived the biological father’s otherwise legally required consent, a stepfather petitioned to adopt his wife’s daughter over the biological father’s objection. The superior court determined that the proposed adoption was not in the child’s best interests and denied the petition. On reconsideration the court noted that the child’s best interests determination was sufficient to deny the petition and concluded that a determination whether the biological father had waived consent was unnecessary, but nonetheless determined…