Matter of Linda F. M., 52 N.Y.2d 236 (1981)
Under Section 114 of the Domestic Relations Law, an adopted person seeking to unseal adoption records must demonstrate “good cause,” which requires more than a mere desire to learn the identity of their biological parents; concrete psychological problems specifically linked to the lack of knowledge about ancestry may constitute good cause.
Summary
Linda F. M., an adopted person, sought to unseal her adoption records, claiming psychological problems stemming from her ignorance of her biological parentage. The New York Court of Appeals held that a mere desire to learn about one’s ancestry does not, by itself, constitute “good cause” to unseal adoption records under Section 114 of the Domestic Relations Law. The court emphasized the importance of protecting the privacy interests of biological parents and the need for a concrete and compelling reason beyond general curiosity.
Facts
Linda F. M. was born in 1940 and adopted in 1941. She learned of her adoption in 1971. In 1977, after other attempts failed, she sought access to her sealed adoption records, alleging psychological problems related to her lack of knowledge about her biological parents.
Procedural History
The Surrogate’s Court found that Linda F. M. failed to establish good cause for unsealing the records. The Appellate Division affirmed the Surrogate’s decision, agreeing that the petitioner had not demonstrated sufficient cause.
Issue(s)
Whether a general desire to learn about one’s ancestry constitutes “good cause” under Section 114 of the Domestic Relations Law to unseal adoption records.
Holding
No, because a mere desire to learn the identity of one’s natural parents does not, alone, constitute good cause, or the requirement of section 114 would become a nullity. However, concrete psychological problems, if specifically connected to the lack of knowledge about ancestry, could constitute good cause.
Court’s Reasoning
The court emphasized the confidential nature of adoption records under Section 114, which serves to protect the adopted child, adoptive parents, and biological parents. This confidentiality shields the child from disturbing facts, allows adoptive parents to develop a close relationship, and provides anonymity for the biological parents.
The court acknowledged the petitioner’s desire to learn about her ancestry but found that her alleged psychological problems were not credibly connected to her lack of knowledge. The court stated, “When balanced against the interests of other parties to the adoption process, however, it cannot alone constitute good cause under section 114.”
The court clarified that “concrete psychological problems, if found by the court to be specifically connected to the lack of knowledge about ancestry, would never constitute good cause.” It emphasized that “good cause admits of no universal, black-letter definition” and must be decided on a case-by-case basis.
The court also addressed the issue of notice to biological parents, stating that such notice should be given if the petitioner makes a showing of entitlement and the biological parents can be located with reasonable effort without revealing their identities to the adoptive parents. This notice allows biological parents to intervene and defend their interest in retaining anonymity.
Finally, the court rejected the petitioner’s claim that Section 114 is unconstitutional, citing Alma Soc. v Mellon.