Wyatt v. McDermott

Wyatt (plaintiff) and Fahland, an unmarried couple, planned to raise their child together after Fahland became pregnant. But Fahland's parents hired attorney McDermott (defendant) to arrange the child's adoption; at McDermott's urging, Fahland signed documents falsely claiming she didn't know Wyatt's address, while continuing to assure Wyatt they'd raise the child together. McDermott arranged for a Utah adoption agency and another attorney to place the baby, and after birth, Utah residents adopted the child without Wyatt ever being informed. After learning of the adoption, Wyatt sought custody and sued for tortious interference with parental rights, among other claims; the district court certified the tortious-interference question to the Virginia Supreme Court.

Whether a common-law claim for tortious interference with parental rights exists when a third party's intentional interference prevents a parent from exercising his or her parental rights, resulting in damages.