B.L. v. J.S., et al Lack of counsel in underlying neglect case is not considered a lack of counsel at all critical states of adoption where the biological parent was not the target of the neglect case and where biological father did not object to adoptive parents being granted full custody of child. Biological father is not a parent exercising custodial control or supervision where he was incarcerated and uninvolved with child for most of child’s life. Court was not required in adoption proceeding to consider less drastic means than adoption. Finally, relatives related only by marriage are nonetheless relatives where statute does not require they be blood relatives and thus there was no error in permitting great-aunt and great-uncle related by marriage to adopt without placement for adoption by the Cabinet.
