Can putative fathers challenge adoption statutes without joining adoptive parents? Carlton v. Brown Explained

In Carlton v. Brown, the Utah Supreme Court addressed whether a putative father could challenge the constitutionality of Utah’s Adoption Act without joining the child’s adoptive parents as parties to the litigation.

Background and Facts

Christopher Carlton and Shalanda Brown, both Pennsylvania residents, were in a romantic relationship that resulted in pregnancy. Four weeks before her due date, Brown left Carlton without notice. Unbeknownst to Carlton, Brown traveled to Utah, gave birth, and relinquished her parental rights to The Adoption Center of Choice. Brown executed a Birth Father Affidavit refusing to identify Carlton and falsely told him their child had died. Carlton discovered the truth months later through a Pennsylvania paternity action, but by then the Utah adoption had been finalized.

Key Legal Issues

The case presented two primary issues: (1) whether Carlton had standing to challenge the constitutionality of Utah’s Adoption Act without joining the adoptive parents, and (2) whether the district court properly dismissed Carlton’s various tort claims. Carlton’s constitutional challenges included facial and as-applied arguments based on due process and equal protection violations.

Court’s Analysis and Holding

The Utah Supreme Court held that Carlton lacked standing to assert his constitutional claims because his injury was not redressable without the adoptive parents’ presence. The court explained that even if Carlton’s constitutional arguments had merit, the court could not grant the requested relief—overturning the adoption and reinstating his parental rights—because neither the adoption center nor the birth mother retained any rights to relinquish. The adoptive parents’ rights would be directly affected, but they were not parties to the proceeding.

However, the court reversed the district court’s denial of Carlton’s motion to amend his petition to add the adoptive parents, finding the denial was an abuse of discretion. The court also reversed the dismissal of Carlton’s intentional infliction of emotional distress claim against the adoption center, as that determination depended on the constitutional issues.

Practice Implications

This decision establishes that constitutional challenges to adoption proceedings require careful attention to necessary parties. Practitioners must ensure adoptive parents are joined from the outset when seeking relief that would affect their rights. The case also demonstrates the importance of the redressability element in standing analysis—courts cannot grant meaningful relief if essential parties are absent from the litigation.