Pham v. Truong
In Pham v. Truong, 291 Ark. 442, 725 S.W.2d 569 (1987), the appellant waited twenty months before he moved to set aside the temporary order of adoption.
Citing what is now Ark. Code Ann. 9-9-216, the court noted that an adoption decree issued for one year or more cannot be questioned by any person, including the petitioner, in any manner or upon any ground unless, in the case of the adoption of a minor, the petitioner has not taken custody of the minor.
The court noted that the appellant made no assertion that he had never taken custody of the adoptee. Thus, his motion to set aside was untimely.