## Facts

- Ronald B. Hunter and Carrie Colaric had an intimate relationship in March 1999; Colaric became pregnant, and Hunter knew of the pregnancy.
- Colaric gave birth on November 26, 1999.
- Two days after birth, Colaric voluntarily terminated her parental rights and consented to the child’s adoption; the child was placed immediately with prospective adoptive parents (“John and Jane Doe”).
- Colaric identified Hunter in adoption-related paperwork as the putative father but stated she did not know his whereabouts and did not know anyone who could locate him.
- The adoptive parents filed a petition to adopt on December 23, 1999.
- The Indiana Putative Father’s Registry was checked during the proceeding; no registration was found for the child, including none by Hunter.
- The trial court finalized the adoption on March 9, 2000, without notice to Hunter.
- On September 25, 2000, Hunter moved to vacate the adoption judgment, arguing he was entitled to notice and that the trial court erred by not appointing counsel; the trial court denied the motion.

## Issues

1. Whether a putative father who did not register with Indiana’s Putative Father’s Registry is entitled to notice of adoption proceedings when the mother identified him as the putative father.
2. Whether the trial court’s failure to appoint counsel for the putative father in connection with his motion to vacate required setting aside the adoption judgment.

## Decision

- The Indiana Court of Appeals affirmed the denial of Hunter’s motion to vacate the adoption judgment.
- The court held that Hunter’s failure to register with the Putative Father’s Registry meant he was not entitled to notice of the adoption proceeding.
- The court held that any error in failing to appoint counsel was harmless because Hunter’s nonregistration was dispositive as a matter of law.

## Legal Principles

- Under Indiana’s putative father registry scheme, timely registration is a condition precedent to a putative father’s right to notice of an adoption proceeding.
- A putative father’s nonregistration results in forfeiture of statutory notice rights, even if the mother identifies him by name in adoption materials.
- A post-judgment request to vacate an adoption decree is reviewed with substantial deference to the trial court, and relief is not warranted absent an abuse of discretion.
- Failure to appoint counsel does not justify vacating an adoption judgment where the alleged error could not have affected the outcome.

## Conclusion

The court enforced Indiana’s registry-based notice framework by holding that a putative father who knew of the pregnancy but did not register had no right to adoption notice, and it left the finalized adoption intact because the counsel issue did not alter the controlling statutory result.


In re J.D.C., 751 N.E.2d 747 (Ind. Ct. App. 2001)