Adoption of Ilona
Massachusetts Supreme Judicial Court
944 N.E.2d 115 (2011)
After a juvenile court terminated Ilona's biological mother's parental rights and approved adoption by her foster parents, the judge found Ilona had a strong bond with her biological mother and that continued contact served her best interest — but also found her prospective adoptive mother warm, nurturing, and committed to supporting that contact unless it began to harm Ilona. Rather than order specific visitation terms, the judge left those decisions to the adoptive parents' discretion. The appellate court agreed adoption should proceed but held a specific visitation order was required; both sides appealed.
Whether courts may leave the specifics of a biological parent's visitation up to a child's adoptive parents rather than setting a specific court order, when the child's best interest does not require otherwise.