Use of Father's Contest In a Subsequent Adoption Proceeding by Other Parties

In In re Custody of Mitchell, 115 Ill. App. 3d at 171, 450 N.E.2d at 370, the respondent consented to the adoption of his son by specified known parties, and there was no language from section 10(C) providing for surrender to an agency. There the court determined the consent was "considerably different" from a surrender to an agency with consent to placement by the agency with unknown parties in section 10(C). In re Custody of Mitchell, 115 Ill. App. 3d at 172, 450 N.E.2d at 370. Moreover, the language of the section 10(A) consent form regarding giving up custody and other parental rights was necessary to effect a transfer of parental rights in an adoption by those specific parties. Notably, the court held, "we do not read this so broadly that it becomes an unconditional relinquishment of parental rights." In re Custody of Mitchell, 115 Ill. App. 3d at 173, 450 N.E.2d at 371. Therefore, the father could contest the use of his consent in a subsequent adoption proceeding by other parties.