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The main issue in this appeal was the trial court's
denial of the mother's motion to open a judgment of voluntary termination
of her parental rights. The mother contended that judgment should
have been vacated because the mother's consent was contingent on
the child being adopted by relative foster parents and the open
adoption agreement between the relatives and the mother, and the
child was ultimately adopted by another couple after the termination
proceeding concluded. The trial court allowed the mother's motion
to be heard and accepted legal briefs on the issues involved. The
court concluded, and the appellate court affirmed, that the mother
had been adequately canvassed during the termination proceeding,
and that the record demonstrated that the mother was aware that
the adoption by proposed relatives was not guaranteed and that an
open adoption agreement was not enforceable by the juvenile court.
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