Nugent v. Powell
In Nugent v. Powell, 4 Wyo. 173, 33 P. 23, 24 (1893), the mother of a child who had been abandoned by the father consented to the child's adoption by a childless couple.
Statutory adoption was pursued to completion, with the exception of the probate court's failure to enter the adoption order of record. Id. at 25.
Upon the intestate death of the adoptive father subsequent to the death of the adoptive mother, the siblings of the deceased adoptive father sought distribution of his estate to themselves, claiming that the child's adoption was ineffective.
The Court reversed the district court's decree favoring the deceased's siblings on the ground that there had been substantial compliance with the adoption statutes. Id. at 25.