B.L. v. J.S.

The state child-welfare agency removed half-siblings B.L. and R.J.P. from their biological mother's care after R.J.P. tested positive for drugs at birth, and the mother stipulated to neglect. The agency placed the children with B.L.'s step-great-aunt and step-great-uncle, J.S. and J.S. (plaintiffs), who then petitioned to adopt them. B.L.'s biological father, B.T.L. (defendant), had been incarcerated throughout the neglect proceedings and for most of B.L.'s life; he objected to the adoption and moved to dismiss the petition. A Kentucky statute lets certain listed relatives adopt a child without the child first being officially placed for adoption, and the trial court granted the adoption under that statute. B.T.L. appealed, arguing among other things that step-relatives are not "relatives" under the statute.