In Re Adoption of Brown

ORS 109.324, quoted in the majority opinion, delineates the criteria under which the necessity for noncustodial parental consent for adoption is determined. The necessity for parental consent is obviated, at the discretion of the court, if the natural parent in question has “wilfully deserted or neglected without just and sufficient cause to provide proper care and maintenance for the child for one year next preceding the filing of the petition for adoption * * The trial court found that the father was divorced by the mother of the children May 22, 1968, and the custody of the children was…