In re N.L.B. v. Lentz: The Missouri Supreme Court's Unwarranted Extension of a Putative Father's Constitutional Protections

In Lentz, the Missouri Supreme Court granted an unwed father leave to intervene in an adoption, despite the fact that he had failed to bring himself into the realm of constitutionally protected putative fathers. This note explains why the holding of the Lentz court subverted the intent of Missouri's adoption statutes and its putative father registry, and argues that an unwed biological father who has not filed a valid paternity action, registered with the putative father registry, or demonstrated a substantial commitment to the responsibilities of parenthood should not be entitled to the additional constitutional protections available to diligent putative fathers. The note will argue that it is not a violation of his constitutional rights to deny such a father leave to intervene in the adoption of his child without a hearing on parental fitness.