Ferdinand v. Department for Children and Their Families
United States District Court for the District of Rhode Island
768 F. Supp. 401 (D.R.I. 1991)
Ferdinand (plaintiff) adopted her daughter through Rhode Island's Department for Children and Their Families (defendant), which had only a minimal conversation with her about available special-needs adoption subsidies; she said she didn't need one at the time, and DCF never formally offered a subsidy or explained the full program, including the option to sign a nominal agreement preserving eligibility for a larger subsidy later. After the adoption finalized and Ferdinand's marriage ended, leaving her without child support, she applied for adoption assistance, but DCF denied it because she had not accepted a subsidy at finalization. Ferdinand sought an injunction ordering DCF to approve her request.
Whether a state has an affirmative duty to fully explain all available adoption-assistance programs to adoptive parents at the time of adoption.