In re the Adoption of Baby Girl S.
This contested adoption proceeding involves Baby Girl S., whose biological mother, M.S. (13/32 Chickasaw Indian), and non-Native American father, D.R., are central figures. Adoptive parents, Adam and Katherine "Anonymous," initiated the adoption. The Chickasaw Nation sought to transfer the case to tribal court and to intervene, while D.R. moved to dismiss the proceeding. The court determined that the Indian Child Welfare Act of 1978 (ICWA) did not apply, primarily due to the "existing Indian family doctrine" and M.S.'s objection to tribal intervention. Consequently, the motions to transfer and dismiss were denied. The Chickasaw Nation was allowed to intervene under CPLR, and a preliminary injunction was granted to the adoptive parents to prevent the child's removal from New York jurisdiction.