In Matter of Tiffany H., 171 Misc 2d 786, 656 NYS2d 792 [Fam Ct, Kings County 1996], the court held it was against public policy to grant standing to a biological mother whose parental rights were terminated because she had not sought "to vacate her default . . . or commence a proceeding in the Surrogate's Court to set aside the adoption" (id. at 792).

If biological parents were "accorded standing to file a custody petition for an adopted child as a third party and thereby overcome the legal consequences attached to the court's findings under . . . Domestic Relations Law § 114 order of adoption . . . the finality of adoptions would be jeopardized forever" (id. at 793).