Florida Statutes
Fla. Stat. § 63.2325 (2025)
Conditions for invalidation of a consent to adoption or affidavit of nonpaternity.
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63.2325 Conditions for invalidation of a consent to adoption or affidavit of nonpaternity.—Notwithstanding the requirements of this chapter, a failure to meet any of those requirements does not constitute grounds for invalidation of a consent to adoption or revocation of an affidavit of nonpaternity unless the extent and circumstances of such a failure result in a material failure of fundamental fairness in the administration of due process, or the failure constitutes or contributes to fraud or duress in obtaining a consent to adoption or affidavit of nonpaternity.
Notes of Decisions
Cited in 6
cases (2 in the last 5 years), 2005–2023 · leading case: J.S. v. S.A., 912 So. 2d 650 (Fla. 4th DCA 2005).
J.S. v. S.A., 912 So. 2d 650 (Fla. 4th DCA 2005). “Although we recognize the serious implications of non-compliance with these statutory provisions governing adoption entities, section 63.2325, Florida Statutes (2004), limits our authority to revoke consent to an adoption based on a failure to comply with statutory requirements.”
In the Interest of I.B., a Child, 142 So. 3d 919 (Fla. 5th DCA 2014). “Section 63.2325, Florida Statutes (2012), provides that the failure to meet a requirement of the adoption statute does not constitute grounds for revocation of consent to adoption "unless the extent and circumstances of such a failure result in a material failure of fundamental…”
C.G. v. Guardian Ad Litem Prog., 920 So. 2d 854 (Fla. 4th DCA 2006). “In fact, this is specifically covered in section 63.2325, Florida Statutes, which states: Notwithstanding the requirements of this chapter, a failure to meet any of those requirements does not constitute grounds for revocation of a consent to adoption or withdrawal of an…”
Js v. Sa, 912 So. 2d 650 (Fla. 4th DCA 2005). “Although we recognize the serious implications of non-compliance with these statutory provisions governing adoption entities, section 63.2325, Florida Statutes (2004), limits our authority to revoke consent to an adoption based on a failure to comply with statutory requirements.”
R.P.M., Adoptive Parent & Elizabeth Berkowitz v. In The Matter of the Proposed Adoption of I.R.M., 376 So. 3d 44 (Fla. 4th DCA 2023). “3 § 63.2325, Fla. Stat. (2021). Notably, section 63.”
M.j.g. v. A. Julia Graves, 332 So. 3d 1008 (Fla. 4th DCA 2022). “Section 63.2325, Florida Statutes, limits the Court’s authority to revoke consent to an adoption based on a failure to comply with statutory requirements unless the extent and circumstances of such failure result in a material failure to fundamental fairness in the…”
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