Petition of SO

I dissent from the court’s upholding the natural father’s consent to the adoption as knowing, intelligent, and voluntary, when, as here, there is substantial evidence in the record of the natural father’s mistaken belief that he would be entitled to exercise continued visitation with his child after the entry of a final decree of adoption.

Because a natural parent has a constitutionally protected liberty interest in the parent-child relationship, Stanley v. Illinois, 405 U.S. 645, 92 S.Ct. 1208, 31 L.Ed.2d 551 (1972), a natural parent’s consent to an adoption must be knowingly, intelligently,…