Cluster 1124533

But see Phariss, 946 P.2d at 1162-63 (rejecting similar separation-of-powers argument where adoptive parents allegedly failed to use reasonable diligence to serve natural father with notice of adoption pro eeedings but ultimately setting aside adoption based on due process violation).

But see Phariss, 946 P.2d at 1162-63 (rejecting similar separation-of-powers argument where adoptive parents allegedly failed to use reasonable diligence to serve natural father with notice of adoption proceedings but ultimately setting aside adoption based on due process violation).

Although this State has a well-recognized interest in providing stability and permanence for children, we are dubious that the General Assembly, in spite of its broad language, intended to permit the termination of constitutionally-protected pa rental rights under circumstances providing less notice to the affected party than is required, for example, to obtain a default judgment on a credit card debt”); In the Interest of S.P., 672 N.W.2d 842, 846, 848 (Iowa 2003) (holding …

(Ind.Ct.App. 2008) 887 N.E.2d 950, 959 ; In re Adoption of Knipper (1986) 30 Ohio App.3d 214, 216 [ 30 Ohio B. 371 , 507 N.E.2d 436 ]; Matter of Adoption of Lori Gay W. (1978) 1978 OK 140 [ 589 P.2d 217, 220 ]; Phariss v. Welshans (1997) 150 Or.App. 498, 503 [ 946 P.2d 1160 ]; F.E. v. G.F.M. (2001) 35 Va.App. 648 , 664-666 [ 547 S.E.2d 531 ].) Others, however, hold to the contrary.

See Phariss v. Welshans, 150 Or App 498, 503 , 946 P2d 1160 (1977) (holding that application of one-year statute of limitations against birth father who received no notice of adoption proceedings violated Due Process Clause).

See Phariss v. Welshans, 150 Or.App. 498, 503 , 946 P.2d 1160 (1997) (permitting biological father to challenge adoption decree several years after its entry).