In re Baby Girl Eason

In In re Baby Girl Eason 257 Ga. 292, 294-295 (1) (358 SE2d 459) (1987), the Supreme Court of Georgia recognized "that there exists a continuum" regarding the interests of unwed biological fathers: ranging from those who take on parental duties and form emotional bonds with their child, and those who do not live with the mother or child, never offer to marry the mother, do not support the child, and fail to register as the father with the state. Although not addressed in Eason, another relevant factor affecting placement on the continuum would likely include whether the father's failure to support and develop a relationship with the child was attributable in some part to actions taken by the mother to impede the father's ability to learn of the child's existence. In In re Baby Girl Eason, the court stated: "Unwed fathers gain from their biological connection with a child an opportunity interest to develop a relationship with their children which is constitutionally protected." Id. at 296. Although the father may abandon this interest, "absent an abandonment of his interest, a state may not deny a biological father a reasonable opportunity to establish a relationship with the child." Id.