Culkin v. Culkin

The mother appeals from an order of the trial court finding that she was unfit, that her consent to adoption was not required and entering a decree granting adoption to petitioners. Petitioner, John Culkin, is the father of the child and Lorraine Culkin is his present wife.

The father has custody under the provisions of a divorce decree entered in the State of Washington. He argues the “best interests” of the child. Absent parental consent or an order finding parental unfitness imder the statute, the “best interests” of the child are not independent grounds for a decree of adoption. In re…