Groves v. Clark

Groves (plaintiff) surrendered her three-year-old daughter, L.C., for adoption by the Clarks (defendants), and the two families signed a visitation agreement giving Groves broad, largely unrestricted access to L.C. The arrangement worked until the Clarks later refused extended visits, prompting Groves to sue for specific performance; the trial court initially found the agreement void, but on appeal the Montana Supreme Court held such agreements enforceable if in the child's best interests and remanded for that analysis. On remand, the trial court found visitation was in L.C.'s best interests but scaled the agreement back to one supervised weekend a month and one weekly phone call, and this appeal followed.