Hall v. Vallandingham
540 A.2d 1162 (1988)

Earl Vallandingham died, leaving behind his wife, Elizabeth, and their four children. Elizabeth then married Jim Killgore, who adopted the children. Twenty-five years after the adoption, Earl’s brother died childless, unmarried, and intestate.

  • The children argued that they were entitled to the distributive share of their natural uncle’s estate.

The Circuit Court determined that the four natural children of Earl, because of their adoption by their adoptive father, Jim Walter Killgore, were not entitled to inherit from William M. Vallandingham Jr.

“Did the trial court err in construing Maryland’s current law regarding natural inheritance by adopted persons so as to deny the Appellants the right to inherit through their natural paternal uncle, when said Appellants were adopted as minors by their stepfather after the death of their natural father and the remarriage of their natural mother?”

  • In other words, are adopted children entitled to the inheritance of their paternal uncle?

No. Affirmed.


  • Adoption is considered a “rebirth” into a completely different relationship.
    • Once a child is adopted, the rights of both the natural parents and relatives are terminated.
    • The adopted child is then entitled to all the rights and privileges of a natural child insofar as the adoptive parents are concerned.
  • Because an adopted child has no right to inherit from the estate of a natural parent who dies intestate, it follows that the same child may not inherit through the natural parent by way of representation.
    • What may not be done directly most assuredly may not be done indirectly.
    • No dual inheritance – adoption does not confer upon the adopted child more rights and privileges than those possessed by a natural child.

Rule: Once a child is adopted, the rights of both the natural parents and relatives are terminated.