Adult Adoption is Entitled to Full Faith and Credit

In Dennis v. Kline, Nos. 4D12–1881 & 4D12–2589, 2013 WL3014115 (Fla. Dist. Ct. App. 2013), the court held that adoption of an adult isentitled to full faith and credit.  A beneficiary of a Florida trustadopted an adult under Pennsylvania law, which, unlike Florida law, does notrequire notice of an adoption to the financially interested parties. The othertrust beneficiaries sought a declaratory judgment excluding the adoptee as apotential beneficiary and obtained a summary judgment in their favor. 

 The Florida intermediate appellate court reversed, holdingthat the Pennsylvania adoption decree was entitled to full faith and credit andthat there was a genuine issue of material fact as to the settlor’s intent withregard to adult adoptees as beneficiaries.

Special thanks to WilliamLaPiana (Professor of Law, New York Law School) for bringingthis case to my attention.