In re R.W.T. Applying for Adoption of J.D

In In re R.W.T. Applying for Adoption of J.D., 594 So. 2d 1383 (La. App. 1992), a stepfather sought to adopt his stepson, thereby terminating the natural father's parental rights. Prior to the time the adoption petition was filed, the natural father spent little time with his son and was delinquent on child support payments. At the adoption hearing, the juvenile court admitted into evidence testimony concerning three incidents between the natural father and his son in which contact with the natural father upset the son, including one incident in which the natural father abducted his son, apparently at gunpoint. The juvenile court found such testimony related to the child's best interests and, after hearing all the testimony, granted the stepfather's petition to adopt his stepson, finding the adoption to be in the child's best interests. On appeal, the natural father argued that the juvenile court erred in admitting postpetition evidence. The Court of Appeal of Louisiana found such testimony to be relevant to the "pivotal issue" of the child's best interests and found the testimony to be relevant on the existence of a parent-child relationship. Id. at 1389.