BILL ANALYSIS                                                                                                                                                                                                    






                           SENATE JUDICIARY COMMITTEE
                            Martha M. Escutia, Chair
                           2003-2004 Regular Session


          AB 2674                                                A
          Assembly Member Leno                                   B
          As Amended June 3, 2004
          Hearing Date:  June 15, 2004                           2
          Family Code                                            6
          GMO:cjt                                                7
                                                                 4

                                     SUBJECT
                                         
                           Adoption:  Relinquishment


                                   DESCRIPTION  

          This bill would provide that an adoption relinquishment  
          that has been sent and filed with the Department of Social  
          Services by certified mail, return receipt requested or by  
          overnight courier with proof of delivery no later than the  
          end of the business day following its execution shall be  
          deemed filed and final five business days after receipt by  
          the department.

                                    BACKGROUND  

          Current law provides for the relinquishment of a child by  
          his or her parent or parents to the Department of Social  
          Services or a licensed adoption agency for the purpose of  
          adoption.  The relinquishment must be signed and properly  
          acknowledged but only after the relinquishing parent has  
          received from the authorized agency counseling and  
          advisement services.  This rule is equally applicable to  
          relinquishing parents that reside in-state and outside of  
          the state.

          The executed relinquishment has no effect until a certified  
          copy is filed with the Department of Social Services.  Once  
          filed, the relinquishment is considered final, and may be  
          rescinded only by mutual consent of the department or  
          licensed adoption agency to which the child was  
                                                                 
          (more)



          AB 2674 (Leno)
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          relinquished and the birth parent or parents relinquishing  
          the child.  The relinquishment is generally incorporated  
          into the petition for adoption of the child, which is filed  
          after the child is placed with the adoptive family.

          However, if the relinquishment identifies the adoptive home  
          into which the child is to be placed, and the child is not  
          placed in that home, the department is obligated to give  
          notice to the relinquishing parent within 72 hours of that  
          decision not to place the child in that adoptive home.  The  
          relinquishing parent, under existing law, has 30 days from  
          the date on which this notice was mailed, to rescind the  
          relinquishment.  If the relinquishing parent does not  
          request rescission by the end of the 30-day period, the  
          department or licensed adoption agency is required to  
          select new adoptive parents for the child.  If the  
          relinquishing parent and the department or licensed  
          adoption agency identify a different adoptive home during  
          the 30-day period, the initial relinquishment is rescinded  
          and a new one executed.

          This bill would address that point in the adoption process  
          where the relinquishment has been properly executed and  
          then sent to the department for filing, which triggers the  
          final effect of the relinquishment and the rest of the  
          provisions relating to rescission of the relinquishment.

                             CHANGES TO EXISTING LAW
           
           Existing law  provides the process by which a birth parent  
          or parents may relinquish a child to the Department of  
          Social Services or to a licensed adoption agency for the  
          purpose of adoption of the child.

           Existing law  provides that a relinquishment has no effect  
          until a certified copy is filed with the department, and  
          once filed, it is final and may not be rescinded except by  
          mutual agreement by the department or the licensed adoption  
          agency and the birth parent.  

           This bill  would require a licensed adoption agency to send  
          a certified copy of the relinquishment to the department,  
          by certified mail return receipt requested or by overnight  
          courier with proof of delivery, no later than the end of  
          the business day following the execution of the  
                                                                       




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          relinquishment.

           This bill  would provide that a relinquishment sent to the  
          department as described would be considered filed and final  
          five business days after it is received by the department.


                                     COMMENT
           
          1.     Need for the bill

              The author states that in practice, the Department of  
             Social Services (DSS) has interpreted the language of  
             the statute (the relinquishment is final when filed) to  
             mean that "the relinquishment is received, then a staff  
             member at DSS reviews the relinquishment to be sure it  
             has been executed properly and then acknowledges  
             receipt.  It is with this acknowledgement that DSS  
             considers the birth parent's decision to terminate their  
             rights is final and binding."  Until recently,  
             supporters and the sponsor of AB 2674 state, the  
             department has been able to process relinquishments  
             received (typically by fax) within two to three days,  
             thus allowing the birth and adoptive parents to move  
             forward with the adoption in reliance on the "permanent"  
             decision about the custody of the baby. 

             There have been "massive lay-offs" at DSS, the author  
             states, and the office responsible for reviewing and  
             acknowledging relinquishments has shrunk dramatically in  
             size.  Presently, supporters say, there is only one  
             staff person and one secretary assigned to respond to  
             all relinquishment packets for the entire state.

             The result of the reduction in staff size is the delay  
             now encountered by the proposed adoptive parents and the  
             birth parents who have relinquished their children for  
             adoption.  According to the author's office the  
             department is now taking anywhere from four to six weeks  
             for a relinquishment to be considered filed and final -  
             a very long time in the context of a young child who is  
             being placed in an adoptive home, and in the context of  
             both sets of parents (birth and adoptive) who are in  
             limbo about the status of this child.

                                                                       




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             This bill hopes to cure this problem by setting a time  
             limit of five business days for the relinquishment to be  
             considered filed and final after it is received by the  
             department.

          2.     Is five business days a realistic time frame,  
             considering departmental budget constraints?  Would this  
             deprive department of needed time to review the  
             propriety of the relinquishment?

              Current law does not set a time limit for the department  
             to process the filing of relinquishments, but this bill  
             would impose a limit of five business days after receipt  
             of the relinquishment, after which the filing would be  
             considered filed and final.

             In order to ensure that the department has received the  
             relinquishment packet, this bill would require the  
             licensed adoption agency to send the relinquishment  
             packet within one business day of its execution, in a  
             manner that provides a proof of receipt, such as  
             registered mail, certified mail return receipt  
             requested, overnight mail with proof of delivery, or by  
             messenger.

             By the proponents' own admission, the department used to  
             be able to process the relinquishments it received in  
             two to three days' time, but now cannot do so because of  
             staff cutbacks.  The Department of Social Services is  
             expected to oppose this bill because the proposed  
             solution would not cure the problem.

             If the department is not able to acknowledge and "file"  
             the certified copy of the relinquishment, the adoptive  
             parents would be able, under this bill, to proceed with  
             the filing of the adoption petition.

             There are two views with regard to the effect of the  
             delayed filing of the relinquishment by the department.   
             One view is that the adoption proceeding is unreasonably  
             delayed, resulting in both adoptive parents and birth  
             parents being left in a state of uncertainty while  
             waiting for the department to act.  Another is that the  
             long waiting period could result in the relinquishing  
             parent or parents changing their minds about the  
                                                                       




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             relinquishment to the adoptive parents and, since the  
             relinquishment is not final until filed, may want to  
             consider different adoptive parents or options, such as  
             a legal guardianship by a relative instead.

             This tension is similar to the one the Committee dealt  
             with when it considered a bill to shorten the time  
             within which consent to adoption may be revoked, from 90  
             days to 30 days.  At the time that bill (SB 104, Scott,  
             Chapter 688, Statutes of 2001) was heard, the proposal  
             was to reduce the revocation time period to 72 hours,  
             but was amended to reduce it instead from 90 days to 30  
             days.

             While the proponents of this bill may wish to shorten  
             the time period for the relinquishment to become final  
             to five business days, it may be unrealistic to expect  
             that the department would be able to handle the workload  
             of complying with the five-day statute.  The fact that  
             the relinquishment would be deemed "final" without  
             review by the department, thus depending solely on the  
             presumed competence and integrity of the licensed  
             adoption agency to provide the necessary protection  
             accorded birth parents, could expose the department to  
             untold liability.  At the least, this process of deeming  
             the filing of a relinquishment final should parallel the  
             time requirement for considering a consent to adoption  
             to be irrevocable, thus permanent and final: 30 days.

             In fact, the Department of Social Services, while not  
             yet ready with an official position, has informally  
             informed the author that it believes that the current  
             statute represents sound public policy and recognizes an  
             important oversight function of the department to ensure  
             the integrity of the relinquishment stage of the  
             adoption process.  The department is "firmly against any  
             timeframe in statute whatsoever?"  The department had  
             indicated it may consider a statute that allows  
             electronic filing, acknowledgment, and confirmation of a  
             properly executed relinquishment.

             SHOULD THE RELINQUISHMENT BE DEEMED FILED AND FINAL 30  
             DAYS AFTER IT IS RECEIVED BY THE DEPARTMENT?  
             This option would give the department ample opportunity  
             to perform its review and provide the stamp of approval  
                                                                       




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             or express concern about the prospective adoptive  
             parents or about the validity of a relinquishment.  It  
             would give both parties (birth and adoptive parents),  
             the licensed adoption agency and the department some  
             finality in the process without creating an unrealistic  
             deadline.  All interested parties may not get the  
             shortened time period they want, but the setting of a  
             deadline provides a solid rule that everybody, including  
             the department, can abide by.

          Support:   San Francisco Jewish Family and Children's  
                  Services; Academy of  California Adoption Lawyers;  
                  American Family Rights Association; California  
                  Alliance of Child and Family Services; Families  
                  Supporting Adoption; Family Law Section of the  
                  State Bar of California; California Association of  
                  Adoption Agencies

          Opposition: None Known

                                     HISTORY
           
          Source: Jewish Family Services

          Related Pending Legislation: None Known

          Prior Legislation: None Known

          Prior Vote: Asm Jud. (Ayes 10, Noes 0)
                    Asm. Floor (Ayes 80, Noes 0) (Consent)

          
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