In re Adoption of P.Y.Y.Y., 2022 IL App (1st) 210791-U

1. Case citation and parties
- In re Adoption of P.Y.Y.Y., 2022 IL App (1st) 210791-U (Ill. App. Ct., 1st Dist. June 21, 2022) (Rule 23 order; non‑precedential).
- Appellant: Brett Ranjel (putative biological father). Appellees: “Husband and Wife” (prospective adoptive parents). Mother: Anna Yordy.

2. Key legal issues
- Whether a putative father who registered with the Illinois Putative Father Registry but did not commence a parentage action within 30 days retains standing/consent rights to block an adoption under the Adoption Act (750 ILCS 50/8).
- Interaction of section 8(b) (consent rules), section 8(a) (waiver language), and section 12a (notice requirements). Constitutional claim: whether denial of standing violated due process/equal protection.

3. Holding/outcome
- The appellate court affirmed the trial court: Ranjel lacked standing to object to the adoption because he failed to file a parentage petition within 30 days of registering with the Putative Father Registry. The mother’s consent alone validated the adoption under section 8(b).

4. Significant legal reasoning (concise)
- Statutory text controls: section 8(b)(1)(A) makes the mother’s consent sufficient; father’s consent is required only if the father meets one of the defined criteria in 8(b)(1)(B). Subsection (vii) conditions father’s consent on timely registry plus commencement of paternity proceedings within 30 days of registration.
- Precedent and legislative history: J.S.A. v. M.H. and Petition of K.J.R. confirm the statutory requirement that putative fathers take specified steps to preserve rights; the statute favors finality and predictability for adoptive parents. Sponsor statements support the policy.
- Section 8(a)/12a arguments rejected: the court held 8(a) does not override the specific sufficiency scheme in 8(b); lack of a separate 12a notice from petitioners did not revive Ranjel’s right after he failed to timely file.
- Due process/equal protection claims fail: the Registry provided notice of the 30‑day filing requirement; inability to pay counsel did not excuse noncompliance.

5. Practice implications for attorneys
- For putative fathers: immediate action is critical—registering is insufficient; commence a parentage action within 30 days of registry entry to preserve standing. Do not rely solely on later notice of adoption.
- For adoptive parents and counsel: confirm registry status and noncompliance in the record; seek rulings on lack of standing early (motion to dismiss/motion for summary determination).
- For litigators: preserve evidence of warnings/registry forms; consider venue strategy (parentage filed in another county may not reinstate standing in adoption court); anticipate and rebut constitutional challenges grounded on inability to pay counsel.