C.G. v. Guardian Ad Litem Program

C.G. appeals an order determining that her consent to adoption of her minor child is valid and binding. She claims that because she was entitled to choose the placement of her child, and the original placement she chose did not occur, her consent is invalid. We hold that C.G.’s consent was irrevocable absent a showing of fraud or duress, which is not present in this case. We therefore affirm.

C.G. is the mother of A.G., who was sheltered by the Department of Children and Families immediately after her birth. The Department alleged that A.G. was in danger of injury due to abuse, abandonment, or…