¶2I agree with the majority that while the reasons to support the rule may differ, the same criteria that apply to natural parents apply to depriving adoptive parents of custody.
¶3Here, the court was not required to make special findings in the absence of a request by either party. Indiana Rules of Procedure, Trial Rule 52; Franks v. Franks (1975), 163 Ind. App. 346, 323 N.E.2d 678. Accordingly, since the record contains substantial evidence of probative value from which the trial court could have concluded that Mrs. Stevenson was unfit, the judgment should be affirmed.
¶4Note. — Reported at 364 N.E.2d 161.
¶5. I would find the res judicata argument inapposite since all the conduct in question occurred after the adoption proceedings were completed.