Alaska Statutes
Alaska Stat. § 25.23.130 (2026)
Effect of adoption decree; effect of termination of parental rights
✓ current as of July 2026
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Sec. 25.23.130. Effect of adoption decree; effect of termination of parental rights.
(a) A final decree of adoption, whether issued by a court of this state or of any other state, has the following effect as to matters within the jurisdiction or before a court of this state:
(1) except with respect to a spouse of the petitioner and relatives of the spouse, to relieve the natural parents of the adopted person of all parental rights and responsibilities, and, except as provided in (c) of this section, to terminate all legal relationships between the adopted person and the natural parents and other relatives of the adopted person, so that the adopted person thereafter is a stranger to the former relatives for all purposes including inheritance, unless the decree of adoption specifically provides for continuation of inheritance rights, and the interpretation or construction of documents, statutes, and instruments, whether executed before or after the adoption is decreed, that do not expressly include the person by name or by some designation not based on a parent and child or blood relationship; and
(2) to create the relationship of parent and child between petitioner and the adopted person, as if the adopted person were a legitimate blood descendant of the petitioner, for all purposes including inheritance and applicability of statutes, documents, and instruments, whether executed before or after the adoption is decreed, that do not expressly exclude an adopted person from their operation or effect.
(b) Notwithstanding the provisions of (a) of this section, if a parent of a child dies without the relationship of parent and child having been previously terminated and a spouse of the living parent thereafter adopts the child, the child's right of inheritance from or through the deceased parent is unaffected by the adoption.
(c) Nothing in this chapter prohibits an adoption that allows visitation between the adopted person and that person's natural parents or other relatives.
(d) Except as provided in (e) and (f) of this section, a decree terminating parental rights on the grounds set out in AS 25.23.180(c)(2) voids all legal relationships between the child and the biological parent so that the child is a stranger to the biological parent and to relatives of the biological parent for all purposes, including interpretation of documents executed before or after the termination of parental rights that do not include the child by name or by a description not based on a parental or blood relationship.
(e) Inheritance rights between a child and a biological parent are not voided by a decree terminating parental rights on the grounds set out in AS 25.23.180(c)(2) unless the decree specifically provides for the termination of inheritance rights.
(f) A decree ordering termination of parental rights between a biological parent and a child on the grounds specified in AS 25.23.180(c)(2) does not relieve the biological parent of an obligation to pay child support unless the decree specifically provides for the termination of the obligation to pay child support. A child support obligation under this subsection does not entitle the obligor to contact or otherwise maintain a relationship with the child.
(a) A final decree of adoption, whether issued by a court of this state or of any other state, has the following effect as to matters within the jurisdiction or before a court of this state:
(1) except with respect to a spouse of the petitioner and relatives of the spouse, to relieve the natural parents of the adopted person of all parental rights and responsibilities, and, except as provided in (c) of this section, to terminate all legal relationships between the adopted person and the natural parents and other relatives of the adopted person, so that the adopted person thereafter is a stranger to the former relatives for all purposes including inheritance, unless the decree of adoption specifically provides for continuation of inheritance rights, and the interpretation or construction of documents, statutes, and instruments, whether executed before or after the adoption is decreed, that do not expressly include the person by name or by some designation not based on a parent and child or blood relationship; and
(2) to create the relationship of parent and child between petitioner and the adopted person, as if the adopted person were a legitimate blood descendant of the petitioner, for all purposes including inheritance and applicability of statutes, documents, and instruments, whether executed before or after the adoption is decreed, that do not expressly exclude an adopted person from their operation or effect.
(b) Notwithstanding the provisions of (a) of this section, if a parent of a child dies without the relationship of parent and child having been previously terminated and a spouse of the living parent thereafter adopts the child, the child's right of inheritance from or through the deceased parent is unaffected by the adoption.
(c) Nothing in this chapter prohibits an adoption that allows visitation between the adopted person and that person's natural parents or other relatives.
(d) Except as provided in (e) and (f) of this section, a decree terminating parental rights on the grounds set out in AS 25.23.180(c)(2) voids all legal relationships between the child and the biological parent so that the child is a stranger to the biological parent and to relatives of the biological parent for all purposes, including interpretation of documents executed before or after the termination of parental rights that do not include the child by name or by a description not based on a parental or blood relationship.
(e) Inheritance rights between a child and a biological parent are not voided by a decree terminating parental rights on the grounds set out in AS 25.23.180(c)(2) unless the decree specifically provides for the termination of inheritance rights.
(f) A decree ordering termination of parental rights between a biological parent and a child on the grounds specified in AS 25.23.180(c)(2) does not relieve the biological parent of an obligation to pay child support unless the decree specifically provides for the termination of the obligation to pay child support. A child support obligation under this subsection does not entitle the obligor to contact or otherwise maintain a relationship with the child.
Notes of Decisions
Cited in 34
cases (4 in the last 5 years), 1985–2025 · leading case: In Re the Adoption of S.K.L.H., 204 P.3d 320 (Alaska 2009).
In Re the Adoption of S.K.L.H., 204 P.3d 320 (Alaska 2009). “Although AS 25.23.130 now does not preclude an ongoing relationship between a biological parent and a child given up for adoption, it still clearly envisions that the adoptive parents in fact become the child's parents.”
Jude M. v. State, Dep't of Health & Soc. Servs., Off. of Child.'s Servs., 394 P.3d 543 (Alaska 2017). “51 See AS 25.23.130 (providing that an adoption decree will “relieve the natural parents of the adopted person of all parental rights and responsibilities, and .”
In Re the Adoption of A.F.M., 960 P.2d 602 (Alaska 1998). “” Farley argues that the superior court interpreted AS 25.23.130(a) and .130(c) “as permitting it to fashion open adoption decrees .”
Osterkamp v. Stiles, 235 P.3d 178 (Alaska 2010). “Ken points to our ruling in Evans to support his argument that the superior court should have made its determination on psychological status based on his entire history with Simon up to the time of trial,.”
Thea G. v. State, Dep't of Health & Soc. Servs., Off. of Child.'s Servs., 291 P.3d 957 (Alaska 2013). “See AS 25.23.130(a)(1); AS 47.10.088(a). 56 The dissent claims that evidence in the record demonstrates that Zach and Abbie were “strongly” or “extremely” bonded to Thea “just before” the termination trial, and that Zach “continually” expressed a fervent desire that the family…”
David S. v. Jared H., 308 P.3d 862 (Alaska 2013). “3d 769, 778 (Alaska 2001) (quoting AS 25.23.130). 48 . In re Adoption of A.F.”
In re W.E.G., 710 P.2d 410 (Alaska 1985). “AS 25.23.130 IS CONSTITUTIONAL The superior court concluded that the adoption statute, AS 25.”
Dennis O. v. Stephanie O., 393 P.3d 401 (Alaska 2017). “See AS 25.23.130(a) ("A final decree of adoption .”
Grace L. v. State, Dept. of Health & Soc. Servs., Off. of Child.'s Servs., 329 P.3d 980 (Alaska 2014). “” See AS 25.23.130(c). 19 Burke P. v. State, Dep’t of Health & Soc.”
Matter of WEG, 710 P.2d 410 (Alaska 1985). “They also contend that the adoption statute, AS 25.23.130, violates equal protection. The boys' biological father argues in favor of the foster parents and against the grandparents.”
State of Alaska, DHSS, OCS v. Zander B & Kelly B. (Foster Parents), 474 P.3d 1153 (Alaska 2020). “2d 410, 416-17 (Alaska 1985) (citing Civil Rule 24(b) and concluding that grandparents should have been allowed to participate as parties in CINA proceedings), superseded by statute on other grounds, AS 25.23.130(c), as recognized in In re A.”
Vest v. State Ex Rel. New Mexico Human Servs. Dep't, 866 P.2d 1175 (N.M. Ct. App. 1993). “Alaska Stat. § 25.23.130 (c) (1991). Only Connecticut's visitation statute could be read to authorize the Vest visitation order, Conn.”
— Alaska Stat. § 25.23.130(a) — 10 cases
Dennis O. v. Stephanie O., 393 P.3d 401 (Alaska 2017). “See AS 25.23.130(a) ("A final decree of adoption .”
In re W.E.G., 710 P.2d 410 (Alaska 1985). “AS 25.23.130 IS CONSTITUTIONAL The superior court concluded that the adoption statute, AS 25.”
Osterkamp v. Stiles, 235 P.3d 178 (Alaska 2010). “Ken points to our ruling in Evans to support his argument that the superior court should have made its determination on psychological status based on his entire history with Simon up to the time of trial,.”
In Re the Adoption of S.K.L.H., 204 P.3d 320 (Alaska 2009). “Although AS 25.23.130 now does not preclude an ongoing relationship between a biological parent and a child given up for adoption, it still clearly envisions that the adoptive parents in fact become the child's parents.”
Matter of WEG, 710 P.2d 410 (Alaska 1985). “They also contend that the adoption statute, AS 25.23.130, violates equal protection. The boys' biological father argues in favor of the foster parents and against the grandparents.”
— Alaska Stat. § 25.23.130(a)(1) — 10 cases
Thea G. v. State, Dep't of Health & Soc. Servs., Off. of Child.'s Servs., 291 P.3d 957 (Alaska 2013). “See AS 25.23.130(a)(1); AS 47.10.088(a). 56 The dissent claims that evidence in the record demonstrates that Zach and Abbie were “strongly” or “extremely” bonded to Thea “just before” the termination trial, and that Zach “continually” expressed a fervent desire that the family…”
In Re the Adoption of S.K.L.H., 204 P.3d 320 (Alaska 2009). “Although AS 25.23.130 now does not preclude an ongoing relationship between a biological parent and a child given up for adoption, it still clearly envisions that the adoptive parents in fact become the child's parents.”
In Re Adoption of Keith MW, 79 P.3d 623 (Alaska 2003).
Rebecca Christy & Samuel Christy v. Charles Conrad & Marcie Conrad, 524 P.3d 231 (Alaska 2023).
In re the Adoption of Xavier K., 268 P.3d 274 (Alaska 2012).
— Alaska Stat. § 25.23.130(a)(2) — 1 case
Osterkamp v. Stiles, 235 P.3d 178 (Alaska 2010). “Ken points to our ruling in Evans to support his argument that the superior court should have made its determination on psychological status based on his entire history with Simon up to the time of trial,.”
— Alaska Stat. § 25.23.130(c) — 11 cases
In Re the Adoption of A.F.M., 960 P.2d 602 (Alaska 1998). “” Farley argues that the superior court interpreted AS 25.23.130(a) and .130(c) “as permitting it to fashion open adoption decrees .”
In Re the Adoption of S.K.L.H., 204 P.3d 320 (Alaska 2009). “Although AS 25.23.130 now does not preclude an ongoing relationship between a biological parent and a child given up for adoption, it still clearly envisions that the adoptive parents in fact become the child's parents.”
Grace L. v. State, Dept. of Health & Soc. Servs., Off. of Child.'s Servs., 329 P.3d 980 (Alaska 2014). “” See AS 25.23.130(c). 19 Burke P. v. State, Dep’t of Health & Soc.”
David S. v. Jared H., 308 P.3d 862 (Alaska 2013). “3d 769, 778 (Alaska 2001) (quoting AS 25.23.130). 48 . In re Adoption of A.F.”
State of Alaska, DHSS, OCS v. Zander B & Kelly B. (Foster Parents), 474 P.3d 1153 (Alaska 2020). “2d 410, 416-17 (Alaska 1985) (citing Civil Rule 24(b) and concluding that grandparents should have been allowed to participate as parties in CINA proceedings), superseded by statute on other grounds, AS 25.23.130(c), as recognized in In re A.”
— Alaska Stat. § 25.23.130(e) — 1 case
In Re the Adoption of A.F.M., 960 P.2d 602 (Alaska 1998). “” Farley argues that the superior court interpreted AS 25.23.130(a) and .130(c) “as permitting it to fashion open adoption decrees .”
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