Carlton v. Brown

Christopher Carlton, a Pennsylvania resident, was in a relationship with Shalanda Brown, who was pregnant with Carlton’s child. Unbeknownst to Carlton, Brown traveled to Utah, where she gave birth to a baby girl and relinquished her parental rights to Adoption Center of Choice, Inc. Because no putative father was registered with respect to the child, Adoption Center commenced and adoption proceedings for the child, which were later finalized. Brown, however, had informed Carlton that the child had died. After Brown subsequently told Carlton that the baby was still alive and had been given up for adoption, Carlton filed an amended petition to establish paternity challenging the constitutionality of the Utah Adoption Act and the extent of the rights it affords to putative fathers who wish to contest adoptions in Utah. The district court dismissed Carlton’s petition based on a lack of standing. The Supreme Court reversed in part, holding that the district court erred in (1) denying Carlton leave to amend his petition to cure standing defects to assert the constitutional claims, and thereby, in dismissing Carlton's constitutional claims; and (2) dismissing Carlton’s claim for intentional infliction of emotional distress. Remanded. View "Carlton v. Brown" on Justia Law