Missouri Court of Appeals, Southern District / Apr 23, 2025
IN THE INTEREST OF A.D.S.: N.A.W., Respondent vs. R.L.S., II, Appellant
N.A.W. (Guardian) petitioned to adopt A.D.S. (Child), alleging Father's consent was not required under section 453.040(7) due to abandonment or neglect. Father appealed the circuit court's judgment granting the adoption, arguing his due process rights were violated because the summons did not notify him of his right to appointed counsel as required by section 211.462. The appellate court affirmed, holding that section 211.462, which pertains to termination of parental rights under chapter 211, is not applicable to an adoption proceeding under section 453.040(7) because chapter 453 does not specifically cross-reference chapter 211 for that ground.