Alaska Stat. » Chapter 25.23
Alaska Statutes

Alaska Stat. § 25.23.070 (2026)

Withdrawal of consent

✓ current as of July 2026
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Sec. 25.23.070. Withdrawal of consent.
 (a) A consent to adoption may not be withdrawn after the entry of a decree of adoption.

 (b) A consent to adoption may be withdrawn before the entry of a decree of adoption, within 10 days after the consent is given, by delivering written notice to the person obtaining the consent, or after the 10-day period, if the court finds, after notice and opportunity to be heard is afforded to petitioner, the person seeking the withdrawal, and the agency placing the child for adoption, that the withdrawal is in the best interest of the person to be adopted and the court orders the withdrawal.




Notes of Decisions
Cited in 6 cases, 1989–2018 · leading case: In Re the Adoption of S.K.L.H., 204 P.3d 320 (Alaska 2009).
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In Re the Adoption of S.K.L.H., 204 P.3d 320 (Alaska 2009). · cites it 4× “See AS 25.23.070(a) (consent may not be withdrawn after entry of adoption decree).”
In Re the Adoption of T.N.F., 781 P.2d 973 (Alaska 1989). · cites it 4× “s argue inter alia that 1) ICWA does not apply to this case since an "Indian family" is not involved, and 2) the one-year statute of limitations in AS 25.23.070 bars the § 1914 action. A. Standard of Review The applicability of ICWA to this case and the question of whether §…”
In Re Adoption of Keith MW, 79 P.3d 623 (Alaska 2003). · cites it 2× “[43] AS 25.23.070(b). ICWA changes the period of withdrawal as a matter of right in consent track cases to the final decree of adoption.”
Agen v. State, Dep't of Revenue, Child Support Enf't Div., 945 P.2d 1215 (Alaska 1997). “The parental duty to support a child is relieved only when another person adopts the child and, as a consequence of the adoption, assumes the obligations to support the child.”
Native Vill. of Napaimute Traditional Council v. Terence W., 79 P.3d 623 (Alaska 2003). · cites it 2× “AS 25.23.070(b). ICWA changes the period of withdrawal as a matter of right in consent track cases to the final decree of adoption.”
Dean S. v. State, Dept. of Health & Soc. Servs., Off. of Child.'s Servs., 420 P.3d 1175 (Alaska 2018). · cites it 5× “DISCUSSION Withdrawal of adoption consent is governed by AS 25.23.070. Subsection (b) of that statute provides: A consent to adoption may be withdrawn before the entry of a decree of adoption, within 10 days after the consent is given, by delivering written notice to the person…”
— Alaska Stat. § 25.23.070(a) — 1 case
In Re the Adoption of S.K.L.H., 204 P.3d 320 (Alaska 2009). “See AS 25.23.070(a) (consent may not be withdrawn after entry of adoption decree).”
— Alaska Stat. § 25.23.070(b) — 4 cases
In Re the Adoption of S.K.L.H., 204 P.3d 320 (Alaska 2009). “See AS 25.23.070(a) (consent may not be withdrawn after entry of adoption decree).”
In Re Adoption of Keith MW, 79 P.3d 623 (Alaska 2003). “[43] AS 25.23.070(b). ICWA changes the period of withdrawal as a matter of right in consent track cases to the final decree of adoption.”
Native Vill. of Napaimute Traditional Council v. Terence W., 79 P.3d 623 (Alaska 2003). “AS 25.23.070(b). ICWA changes the period of withdrawal as a matter of right in consent track cases to the final decree of adoption.”
Dean S. v. State, Dept. of Health & Soc. Servs., Off. of Child.'s Servs., 420 P.3d 1175 (Alaska 2018). “DISCUSSION Withdrawal of adoption consent is governed by AS 25.23.070. Subsection (b) of that statute provides: A consent to adoption may be withdrawn before the entry of a decree of adoption, within 10 days after the consent is given, by delivering written notice to the person…”
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