## Facts

- Camille (a minor) gave birth to D.N.T. (“Diane”) in September 1999 in Texas.
- After Diane’s birth, Camille and Diane lived in multiple states, including time in Arizona with Camille’s mother, Sally (Diane’s maternal grandmother).
- While in Arizona, Sally obtained guardianship paperwork through a store-bought, do-it-yourself packet largely so Diane could obtain insurance coverage through Sally.
- Camille and Diane later moved to Mississippi and lived with a married couple, Rick and Carol, who provided complete financial support for Camille and Diane and helped care for Diane.
- While living with Rick and Carol, Camille had a boyfriend, Calvin, and spent significant time with him.
- In early 2001, conversations began about Rick and Carol adopting Diane. Calvin discouraged Camille from proceeding, offering to marry Camille and raise Diane as his own child.
- Rick and Carol retained an attorney to prepare adoption documents.
- In March 2001, Camille went to the attorney’s office with her adult/college-aged sister, Denise. Denise told Camille she did not have to sign and said she would not proceed with an adoption if she were in Camille’s position.
- Camille read the documents, including a written surrender of her parental rights, and signed them. She also joined in the adoption complaint filed by Rick and Carol.
- Shortly after signing, Camille called Sally in Arizona and said she had second thoughts about the adoption.
- Sally traveled to Mississippi. After Sally arrived, Camille told Rick and Carol that she had changed her mind.
- Rick and Carol refused to return Diane and continued with the adoption process.
- Camille and Sally filed a chancery-court complaint to revoke Camille’s consent and to obtain custody. Rick and Carol moved to dismiss.
- The chancellor made detailed findings, dismissed Camille and Sally’s action, and granted Rick and Carol a permanent adoption decree. Camille and Sally appealed.

## Issues

1. Whether Mississippi’s chancery court had authority to proceed with and finalize the adoption despite the grandmother’s earlier Arizona guardianship paperwork.
2. Whether a minor natural mother who executed a written surrender/consent and joined in the adoption petition could revoke that consent based on a later change of mind.
3. Whether the chancellor’s findings that the surrender was voluntary and that the adoption should be finalized were supported by the evidence under the appellate standard of review.

## Decision

- The Mississippi Supreme Court affirmed.
- The Court held the chancery court properly exercised authority over the adoption and was not displaced by the Arizona guardianship paperwork obtained for administrative purposes.
- The Court upheld the chancellor’s determination that Camille’s written surrender and consent were knowingly and voluntarily executed, despite her minority and later regret.
- The Court agreed that the record did not require setting aside the surrender on grounds such as fraud or duress and that the chancellor’s factual findings and credibility determinations were not manifestly wrong.
- The dismissal of Camille and Sally’s revocation/custody complaint and the judgment granting the permanent adoption to Rick and Carol were left in place.

## Legal Principles

- Mississippi adoptions are statutory; when a natural parent executes a written surrender/consent that meets statutory requirements, later regret alone is not enough to revoke it.
- A minor’s age does not automatically invalidate a written surrender/consent where the evidence supports that the minor read the documents, understood their effect, and signed voluntarily.
- A foreign guardianship arrangement—especially informal paperwork used to obtain benefits such as insurance—does not automatically bar a Mississippi adoption when the child and adoptive petitioners are properly before the Mississippi chancery court.
- On appeal, Mississippi gives substantial deference to chancery-court factfinding and credibility calls in domestic matters; supported findings will not be reversed absent manifest error.

## Conclusion

In *In re Adoption of D.N.T.*, the Mississippi Supreme Court affirmed a permanent adoption after concluding that the minor mother’s written surrender and consent—executed after she read the documents and was told she did not have to sign—could not be undone simply because she quickly changed her mind, and that the grandmother’s earlier Arizona do-it-yourself guardianship paperwork did not prevent the Mississippi chancery court from finalizing the adoption.


In re Adoption of D.N.T., 843 So. 2d 690 (2003)