In re the Appeal in Maricopa County, Juvenile Action No. A-26961

OPINION

MEYERSON, Judge.

This appeal is from an order entered in an adoption proceeding wherein the court ruled that the natural mother’s written consent to permit adoption of her two children was not the result of fraud, duress, or undue influence. The mother argues on appeal that (1) the evidence was insufficient to support the trial court’s ruling and (2) under Santosky v. Kramer, 455 U.S. 745, 102 S.Ct. 1388, 71 L.Ed.2d 599 (1982), the burden of proof was on the adoptive parents to show by clear and convincing evidence that the consent was voluntary. However, we do not reach these issues…