In re Adoption of B.H., 2020 UT 64 (Sept. 16, 2020)

Citing the Uniform Child Custody Jurisdiction and Enforcement Act, a biological father argued Utah lacked jurisdiction over a petition to terminate his parental rights, because the child was born in Montana. The district court had jurisdiction over the termination of parental rights because the action was filed under the Adoption Act and, as a result, was not governed by the UCCJEA. The supreme court went on to hold that a material deficiency in a form required by the Interstate Compact on the Placement of Children does not divest the district court of subject matter jurisdiction.