Quilloin v. Walcott
In Quilloin v. Walcott, 434 U.S. 246 (1978), the U.S. Supreme Court affirmed an adoption by a stepfather of a child despite the objection of his natural father. The Court affirmed denial of the father's petition for legitimation, because the Court embraced the "best interests of the child" standard.
The Court noted, however, that it "has recognized on numerous occasions that the relationship between parent and child is constitutionally protected." Id. at 255.