In re Adoption of M.S.M.-P. (Majority and Concurrence)
Annotate this CaseM.S.M.-P. was born in April 2000. His biological parents, S.K. and N.P.'s relationship was marked from the beginning by physical abuse against S.K. S.K. and N.P.'s relationship ended within two weeks of M.S.M.-P.'s birth. During the first three years of M.S.M.-P.'s life, N.P. visited him fewer than 10 times, and he had not seen or had any contact with him since then. In 2002, when M.S.M.-P. was two years old, his mother S.K. began a relationship with A.K. S.K., A.K., and M.S.M.-P. lived together as a family since 2003, and S.K. and A.K. married in 2008. A.K. has cared for M.S.M.-P. since they began living together and has been the only father M.S.M.-P. has known. S.K. and A.K. have had two other children together. In early 2010, A.K. decided to adopt M.S.M.-P. and sought N .P. 's consent. After N .P. refused to consent to the adoption, A.K. filed a petition to terminate N.P.'s parental rights and to obtain permanent custody with the right to adopt. S.K. joined in the petition. In 2012, N.P.'s parental rights to M.S.M.-P. were terminated in a closed proceeding. N.P. 's attorney affirmatively consented to the closure, and soon afterward, M.S.M.-P. was adopted by his stepfather. N.P. sought reversal because the trial court closed the proceeding without analyzing the "Ishikawa" factors. After review, the Supreme Court concluded N .P. waived his right to open proceedings under article I, section 10 of the Washington Constitution.
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