Michels v. Hodges

At issue in this case is whether a child may be adopted without the consent of his father or satisfaction of any of the exceptions to the consent requirement contained in the adoption statutes. The trial court held that, because father engaged in conduct that would have resulted in termination of his parental rights, neither consent nor satisfaction of any of the statutory exceptions to consent was necessary. The court then entered judgment allowing child’s adoption by petitioners. We conclude that the trial court erred in holding that consent or satisfaction of the statutory exceptions to…