## Facts

- A Black child was placed for adoption shortly after birth and lived with white foster parents who petitioned to adopt.
- The child’s Black paternal grandparents filed a competing adoption petition after learning of the adoption plan; the biological father objected to the foster parents’ petition and supported the grandparents.
- The District of Columbia Department of Human Resources placed the child with the foster parents and supported their adoption petition.
- A District of Columbia statute permitted courts to consider race as a factor in adoption best-interest determinations.
- The trial court granted the grandparents’ petition and denied the foster parents’ petition, reasoning in substantial part that placement with white parents could cause future racial-identity difficulties for the child.

## Issues

1. Whether the trial court properly applied the “best interests of the child” standard in selecting between competing adoptive petitioners.
2. Whether the trial court permissibly considered race under District of Columbia law, and what weight race may receive in the best-interests analysis.
3. Whether the trial court erred by giving decisive weight to speculative future racial-identity concerns rather than the child’s present attachments, stability, and developmental needs.

## Decision

- The District of Columbia Court of Appeals reversed the adoption order granting the grandparents’ petition and denying the foster parents’ petition.
- The court held that race may be considered under the statute, but the trial court misapplied the best-interests standard by allowing race and speculative identity concerns to dominate the analysis.
- The case was remanded for further proceedings consistent with the appellate court’s guidance on the limited role of race in best-interests determinations.

## Legal Principles

- The child’s best interests are the controlling consideration in adoption proceedings; competing adult preferences yield to the child’s welfare.
- When a statute permits consideration of race, race is a permissible factor but is not dispositive and may not be treated as an automatic preference.
- Courts must focus on concrete, present indicators of the child’s welfare—such as emotional bonds, continuity of care, and the likely psychological impact of disrupting an established placement—rather than speculative future harms.
- Appellate deference to trial-court best-interests findings does not extend to legal error, including the use of an incorrect standard or treating a permitted factor as controlling.

## Conclusion

The court reversed because the trial court effectively made race determinative in a contested adoption, contrary to a best-interests framework that requires race to remain one factor among many and not to outweigh established attachment and stability considerations.


In re R.M.G., 454 A.2d 776 (D.C. 1982)