In Johnson v. Eidson, the Georgia Supreme Court held that "moral unfitness" of natural parents is not an exception to the statutory prerequisite that natural parents consent to their children's adoption.
The maternal grandparents of Lewis and Jimmy Lynn Johnson had petitioned the court to allow them to adopt their grandchildren without the consent of the natural parents. Their petition was based on (1) their temporary custody of the children, which was granted by a juvenile court after the children had been found in a condition of neglect; (2) abandonment by the natural parents; and (3) the unfit and improper activity of the natural parents. Over the objections of the natural parents, the trial court found the parents to be morally unfit, the grandparents to be morally fit and financially able, and the adoption to be in the best interest of the child. The petition was granted.
Gibson, Susan W.
"Consent of 'Unfit' Parents Needed for Adoption—Unless Their Rights Are First Terminated,"
Mercer Law Review: Vol. 28:
2, Article 13.
Available at: https://digitalcommons.law.mercer.edu/jour_mlr/vol28/iss2/13