H.  Revocation of Relinquishment

C.R.S. § 19-5-104(7)(a)
Parents may revoke a relinquishment induced by fraud or duress. They must request revocation within 90 days of the entry of the relinquishment order. If a parent can prove fraud or duress by clear and convincing evidence, the court may invalidate the relinquishment. 

C.R.S. § 19-5-104(8)
In such a case, if the parent’s rights cannot be terminated involuntarily, the court may then dismiss the adoption proceeding and award custody based on the child’s best interests.

C.R.S. § 19-5-104(6), 7(b) and (9)
Otherwise, the relinquishment order is final and irrevocable. It may not be revoked because the relinquishing parent is a minor. It also may not be revoked if the relinquishing parent knew but did not disclose the other parent’s name or whereabouts.

25 U.S.C.A. § 1913
25 U.S.C.A. § 1916
An Indian child’s parents may revoke consent to adoption.  Indian Child Welfare Act provisions are summarized below:
  • If an Indian child’s adoption is not yet final, the parent or Indian custodian may revoke the consent at any time, and the court must return the child to the parent or Indian custodian.
  • If an Indian child’s adoption has been final less than two years, the parent or Indian custodian may revoke the consent if it was obtained through fraud or duress, and the court must return the child to the parent or Indian custodian.
  • If an Indian child’s adoption has been final for two years, the parent or Indian custodian may not revoke the consent, and the court must reject requests to revoke.
  • If an Indian child’s adoption is set aside or vacated, the parent or Indian custodian may petition for return of the child, and the court must grant the petition unless there is a showing that it would not be in the best interests of the child.