The instant case is distinguished from Memphis Planned Parenthood Inc. v. Sundquist because in Planned Parenthood the court protected anonymity in matters regarding a fundamental unlisted constitutional right, abortion. Birth parent confidentiality is not required by either the Constitution or the Supreme Court, because the right to place a child for adoption is not a recognized constitutional right. Plaintiffs have not briefed this cause of action, so their contentions are unclear. Birth parents who placed their children for adoption by definition have no parental rights, since they surrendered their parental rights during the adoption proceedings.
Adoption agencies have no parental rights.