## Facts

- Dale Heidbreder (putative father) and Katie Carton (birth mother) conceived a child while unmarried.
- During the pregnancy, Heidbreder provided no pregnancy-related financial support; the relationship ended, and Carton moved from Iowa to Minnesota without telling him her whereabouts.
- The child was born in Minnesota on August 12, 2000; Carton did not identify Heidbreder on the birth certificate and arranged an adoption placement with M.J.P. and M.B.P., who filed an adoption petition and took the child from the hospital.
- Minnesota requires a putative father to register with the Minnesota Fathers’ Adoption Registry within 30 days of birth to receive notice of adoption proceedings and preserve certain rights.
- On day 31 after birth, Heidbreder learned from a third party of the birth and adoption placement; he immediately registered and filed a paternity action.
- The adoptive parents moved to dismiss, asserting the late registration extinguished Heidbreder’s right to notice and to contest the adoption; Heidbreder argued concealment and constitutional violations excused the untimely filing.

## Issues

1. Whether registering with the putative-father registry on the 31st day could be excused to preserve the right to notice of adoption and to maintain a paternity action.
2. Whether the birth mother’s alleged concealment and nondisclosure constituted fraud or fraudulent nondisclosure sufficient to toll the statutory deadline or support equitable relief.
3. Whether denying notice and rights based on failure to meet the 30-day deadline violated substantive due process, procedural due process, or equal protection.

## Decision

- The Minnesota Supreme Court affirmed summary judgment for the adoptive parents and dismissal of the paternity action.
- The court held the registration was untimely and Heidbreder failed to prove by clear and convincing evidence that timely registration was impossible or that failure to register was through no fault of his own.
- The court held the record did not establish fraud or fraudulent nondisclosure that would toll the deadline or support relief.
- The court rejected due process and equal protection challenges, concluding the statutory scheme was constitutional as applied.

## Legal Principles

- A putative father must comply with the statutory registry deadline to obtain notice of adoption proceedings and preserve the ability to assert parental rights.
- Relief from a missed registration deadline requires clear and convincing proof that compliance was not possible or that the failure occurred through no fault of the father.
- Fraud requires proof of a false representation of a past or present material fact, intent to induce reliance, actual reliance, and resulting damages; nondisclosure supports fraud only when the defendant had a legal or equitable duty to disclose and the plaintiff was entitled to the information.
- The “unclean hands” doctrine bars a party with inequitable conduct from obtaining equitable relief; it does not prevent that party from opposing another’s request for equitable relief.
- A biological connection alone does not guarantee full constitutional protection for an unwed father; the state may require prompt formal action to demonstrate commitment and may condition notice on compliance with reasonable procedural requirements.
- Under rational-basis review, a registry deadline that advances timely, stable adoptions and procedural certainty does not violate equal protection.

## Conclusion

The court enforced Minnesota’s 30-day putative-father registry deadline strictly, holding that a one-day-late registration barred notice and participation in the adoption because the father did not prove timely registration was impossible or faultless, and because the alleged concealment did not satisfy fraud doctrines; the statute also withstood due process and equal protection challenges.


Heidbreder v. Carton, 645 N.W.2d 355 (Minn. 2002)