Editor's notes.

- In light of the similarity of the statutory provisions, decisions under Ga. L. 1941, p. 300, § 9 and former § 19-8-10, as last amended by Ga. L. 1988, p. 864, § 2, are included in the annotations for this Code section.

One who objects to proceeding must establish blood relationship to child. McDonald v. Hester, 115 Ga. App. 740, 155 S.E.2d 720 (1967) (decided under Ga. L. 1941, p. 300, § 9 prior to revision of chapter by Ga. L. 1977, p. 201).

Standing to object when babies inadvertently switched in hospital.

- Parents who adopted petitioner's child, after the child had been inadvertently exchanged with another woman's baby in the hospital shortly after delivery, were not "related by blood" to the other woman's child and had no authority to object when petitioner sought to adopt the other woman's child, whom she had loved and cared for since she left the hospital with that child. Pope v. Moore, 261 Ga. 253, 403 S.E.2d 205 (1991) (decided under former § 19-8-10, as last amended by Ga. L. 1988, p. 864, § 2).

Relatives of child may not object to adoption as long as one natural parent is living and has consented, and may not intervene in action as they lack required interest in adoption. Lockey v. Bennett, 244 Ga. 339, 260 S.E.2d 56 (1979) (decided under Ga. L. 1941, p. 300, § 9); Brant v. Bazemore, 173 Ga. App. 294, 325 S.E.2d 905 (1985);(decided under former § 19-8-10, as last amended by Ga. L. 1988, p. 864, § 2).

Relatives had standing to object when "legal father" not established.

- Maternal great aunt and uncle had standing to file objections to an adoption petition of aunt and uncle who had obtained a written surrender of rights from the child's putative biological father; the latter was not the "legal father" as defined by O.C.G.A. § 19-8-1. Echols v. Cochran, 214 Ga. App. 348, 447 S.E.2d 700 (1994).

Former husband lacked standing to object to adoption.

- When former husband had no blood relationship to the child, the natural father had surrendered his parental rights to present husband, and his wife, the natural mother, consented to the adoption, the former husband had no standing to object to the adoption. Kelly v. Silverstein, 207 Ga. App. 381, 427 S.E.2d 851 (1993).

O.C.G.A. § 19-8-15 does not limit the court's authority to award grandparent visitation pursuant to O.C.G.A. § 19-7-3. O.C.G.A. § 19-8-15 pertains to objections that certain relatives of the child sought to be adopted may make to the petition to adopt in those circumstances when both of the child's parents are either deceased or no longer have parental rights. Evans v. Sangster, 330 Ga. App. 533, 768 S.E.2d 278 (2015).

Grandparent lacks standing to object to adoption while natural parent is in life, and it is error to allow a grandparent to file objections to a petition, even if the grandparent has an interest in seeing his blood line continue into the future. Hester v. Mathis, 147 Ga. App. 257, 248 S.E.2d 538 (1978) (decided under Ga. L. 1941, p. 300, § 9).

Grandparents may file objections to petitions for adoption only if there is no father or mother living; otherwise, they have no standing to object. Mead v. Owens, 149 Ga. App. 303, 254 S.E.2d 431 (1979) (decided under Ga. L. 1941, p. 300, § 9).

Grandparents were not statutorily authorized to intervene in adoption proceedings brought by a married couple who were not blood relatives of the child since the child's parents were living, and the grandparents did not intervene to seek visitation rights, but instead intervened to object to the adoption and to seek to adopt the child themselves. Murphy v. McCarthy, 201 Ga. App. 101, 410 S.E.2d 198 (1991).

Grandmother who was temporary legal custodian of child under juvenile court deprivation order did not have standing to intervene in adoption proceedings. Edgar v. Shave, 205 Ga. App. 337, 422 S.E.2d 234 (1992).

O.C.G.A. § 19-7-1(b.1) did not give grandparents the right to intervene in adoption proceedings brought by third parties after the parents had voluntarily surrendered their parental rights and agreed to the adoption. Baum v. Moore, 230 Ga. App. 255, 496 S.E.2d 307 (1998).

Superior court erred in permitting the paternal grandparents of a minor child to intervene in the third party's petition to adopt the child because O.C.G.A. § 19-8-15 did not give the grandparents standing to object to the adoption as the child's legal mother was alive and the legal mother had consented to the adoption; the grandparents' objections could only be made when a blood relative filed for adoption of the minor child, and the third party was not a relative; and the grandparents did not establish any visitation rights to the child. McDowell v. Bowers, 342 Ga. App. 811, 805 S.E.2d 136 (2017).

Construction with other law.

- Superior court properly dismissed a grandmother's adoption petition on collateral estoppel grounds based on the juvenile court's previous order granting temporary custody to the maternal grandfather and grant of visitation rights to the grandmother; as a result, the superior court was not authorized to readjudicate the issue of permanent custody involving the child at issue. Smith v. Hutcheson, 283 Ga. App. 117, 640 S.E.2d 690 (2006).

Standing to appeal.

- Appellate court denied the adoptive parents' motion to dismiss the appeal filed by a blood relative because the relative was a party and had standing to appeal as the relative was served with a summons, the relative filed a response to the adoptive parents' petition, and the trial court ordered the relative to undergo a psychological examination and submit to a home evaluation. Parker v. Stone, 333 Ga. App. 638, 773 S.E.2d 793 (2015).

Am. Jur. 2d.

- 2 Am. Jur. 2d, Adoption, § 148.

C.J.S.

- 2 C.J.S., Adoption of Persons, § 121.

ALR.

- Sum set apart in connection with self-insurance as deductible in computing income tax, 76 A.L.R. 1067.

Who, other than natural or adopting parents, or heirs of latter, may collaterally attack adoption decree, 92 A.L.R.2d 813.