What constitutes good cause to unseal adoption records in Utah? In re M.A. Explained

In In re M.A., the Utah Supreme Court clarified the standard for unsealing adoption records, rejecting a district court’s attempt to impose additional requirements beyond the statutory good cause standard.

Background and Facts

Marianne Tyson was adopted in 1978 as an infant. Forty-four years later, she petitioned to unseal her adoption records to obtain “health, genetic, or social information” about her birth parents. Her doctors had requested family medical history regarding menopause, high blood pressure, and stroke, which she could not provide due to her adoption. The Utah Adoption Registry could not find a parental match through its voluntary system.

Key Legal Issues

The case presented two primary issues: (1) whether the best interest of the child standard or the good cause standard applies to petitions for unsealing adoption records, and (2) what constitutes “good cause” under Utah Code § 78B-6-141(3)(c) for unsealing sealed adoption records.

Court’s Analysis and Holding

The Utah Supreme Court first determined that the good cause standard, not the best interest of the child standard, governs petitions to unseal adoption records. Applying the canon that specific statutory provisions control over general ones, the Court held that § 78B-6-141(3)(c)’s specific good cause requirement supersedes the general best interest language in § 78B-6-102(1).

More significantly, the Court rejected the district court’s interpretation that good cause requires “something more than a desire to obtain health or genetic or social information unrelated to a specific medical condition.” The Court explained that the Legislature already balanced privacy interests against disclosure by establishing the good cause standard, and courts cannot impose additional categorical requirements.

The Court also found error in the district court’s Rule 107 balancing, noting that the court focused solely on the birth mother’s privacy interests without considering Tyson’s reasons for disclosure.

Practice Implications

This decision provides important guidance for practitioners handling adoption record unsealing cases. Courts must apply the statutory good cause standard as written, without imposing additional requirements that would effectively rewrite the statute. The undefined nature of “good cause” provides courts with broad discretion to consider individual case facts, but that discretion cannot be used to create categorical exclusions not found in the statute.