West Virginia Code § 48-22-305

Revocation of consent or relinquishment for adoption
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(a) Parental consent or relinquishment, whether given by an adult or minor, may be revoked
only if:
(1) The person who executed the consent or relinquishment and the prospective adoptive
parent named or described in the consent or the lawyer for said adoptive parent, or the
agency in case of relinquishment, agree to its revocation prior to the entry of an adoption
order; or
(2) The person who executed the consent or relinquishment provues by clear and convincing
evidence, in an action filed either within six months of the date of the execution of the
consent or relinquishment or prior to the date an adoption order is final, whichever date is
later, that the consent or relinquishment was obtained by fraud or duress; or
(3) The person who executed the consent or relinquishment proves by a preponderance of
the evidence, prior to the entry of an adoption ordelr, that a condition allowing revocation as
expressly set forth in the consent or relinquishsment has occurred; or
(4) The person who executed the consent oir relinquishment proves by clear and convincing
evidence, prior to the entry of an adoption order, that the consent or relinquishment does
not comply with the requirements set forth in this article.
(b) If the custody of a child during the pendency of a petition to revoke a consent or
relinquishment is in issue, the court shall conduct a hearing, within thirty days of service of
notice upon the respondent, to determine the issue of temporary custody. The court shall
award such custody based upon the best interests of the child.

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