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Try CasePortal for FreeJ. Combs finds the appeals court improperly vacated the trial court in an underlying action, in which a mother sought to have her husband adopt her out-of-wedlock child without the consent of the natural father. Though the appeals court agreed there was insufficient evidence the father willfully failed to support, it also found the mother had established a case the father did not maintain a substantial and positive relationship with the child. Evidence shows the mother would not give the father her address and blocked him on her phone and social media, and the father thought she and the child were living in another city based on the information he had. The trial court made no specific finding as to the sufficiency of the father's legal efforts to establish a relationship. Vacated.