State ex rel. B.B
In State ex rel. B.B., 2004 UT 39, 94 P.3d 252, the Hardingers had visitation rights under a preadoption order, but those rights were not memorialized in the final adoption decree issued to a second couple, the Scotts. Id.
The Hardingers sought an order to show cause, requiring that the Scotts appear in juvenile court to explain why their violation of the preadoption visitation order did not constitute contempt. Id. The juvenile court asserted jurisdiction and ordered visitation pursuant to the preadoption visitation order. Id.
The court of appeals reversed, finding that the juvenile court had no jurisdiction to hear the claim, and we agreed. Id.
Focusing on the fact that juvenile courts have limited jurisdiction because they are creatures of statute, id. the Courtheld that an adoption decree is a final order that alters the legal relationship between the parents, the child, and the court, id. "Once the legal relationship of parent and child is established, the juvenile court lacks subject matter jurisdiction over the adopted child until new requirements for jurisdiction are satisfied." Id.
By operation of statute, the adoption order terminated the jurisdiction of the juvenile court over the adopted child, id.; accordingly, the juvenile court lacked subject matter jurisdiction to hear the Hardingers' order to show cause; id.. Consistent with this analysis, the Court also held that the juvenile court lacked jurisdiction to award costs. Id.