In Adoption of Jacob C

In In Adoption of Jacob C. (1994) 25 Cal.App.4th 617, the mother absconded with one of two children whose custody had been awarded to the father. The trial court subsequently granted the stepmother's petition to adopt the other child, and the mother appealed from the order terminating her parental rights. The reviewing court applied the disentitlement doctrine, reasoning that "no one has prevented the mother from appearing and contesting the petitions in this case. She has received both notice and an opportunity to be heard, the essentials of procedural due process; she alone now possesses the power to end her exclusion from the hearing, simply by coming out of hiding and making a personal appearance. Her refusal to do so clearly constitutes precisely the kind of 'flagrant disobedience and contempt' of judicial processes which bar her from seeking any court assistance in hearing her claims." ( Id. at p. 623.)