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Massachusetts law is instructive. Numerous court decisions have expressed an understanding that judges may effect or require postadoption visitation as an outcome of termination proceedings. See, e.g., Adoption of Vito, 47 Mass. App. Ct. 349, 354-355, 712 N.E.2d 1188 (1999); Adoption of Lars, 46 Mass. App. Ct. 30, 34-36, 702 N.E.2d 1187 (1998); Adoption of Hugo, 44 Mass. App. Ct. 863, 865, 868, 694 N.E.2d 377, S. C., 428 Mass. 219, 700 N.E.2d 516 (1998), cert. denied sub nom. Hugo P. v. George P., 526 U.S. 1034, 119 S. Ct. 1286, 143 L. Ed. 2d 378 (1999); Adoption of Warren, 44 Mass. App. Ct. 620, 626 n.5, 693 N.E.2d 1021 (1998); Adoption of Nicole, 40 Mass. App. Ct. 259, 264, 662 N.E.2d 1058 (1996); Adoption of Arthur, 34 Mass. App. Ct. 1105, 608 N.E.2d 1066 (1993); Adoption of Gwendolyn, 29 Mass. App. Ct. 130, 137 n.5, 138-139, 558 N.E.2d 10 (1990). See also Adoption of Kristin, 43 Mass. App. Ct. 915, 915-916, 683 N.E.2d 1048 (1997) (assuming power of probate judge to establish mechanism for biological mother to request postadoption visitation of adoptive parents and for adoptive parents to respond); Adoption of Abigail, 23 Mass. ...
