In the Matter of the Adoption of T.m.m.h.

Summary

The court affirmed the denial of the grandmother's participation in a stepparent adoption because she failed to establish statutory standing as an interested party and failed to preserve or adequately support her alternative theories. The court held that adoption appeals require both statutory and common-law standing, but resolved the case solely on the statutory prong and did not decide whether the grandmother's agreements or relationship with the child could establish parenthood. Rosen, J., and Johnson, J., dissenting, would have found a prima facie showing of standing and remanded for an evidentiary hearing.