Matter of Donald U

In Matter of Donald U., (105 AD2d 875 [3d Dept 1984], lv dismissed 64 N.Y.2d 603 [1985]), an adoption case in which the only issue before the court was "the best interest of the child" (id. at 876), the prospective adoptive father not only had a criminal record, but had also received a less than honorable discharge from the military for going AWOL and stealing a car. Although the court noted that these facts were "hardly praiseworthy," the court nevertheless approved certification primarily because the crimes had occurred many years prior to the adoption proceeding.