T.M.

I. INTRODUCTION

A biological father who does not qualify as a statutory presumed father, but who also has not been shown to be an unfit parent, is constitutionally entitled *675 to prevent the termination of his parental rights if, as soon as he knew or should have known of the mother’s pregnancy, he demonstrated a full commitment to his parental responsibilities. This entitlement may also exist when the father’s attempt to demonstrate such a commitment is unilaterally frustrated by the child’s mother.

In this case, a biological father’s effort to assume his parental responsibilities was frustrated, in part, by the child’s mother, who broke off their relationship and decided to relinquish the child for adoption. However, the father’s ability to demonstrate his commitment was impeded to a far greater extent by the predictable consequences of his own criminal activity. Under these circumstances, we hold that the father did not make a showing of commitment to his parental responsibilities sufficient to entitle him to a hearing on his fitness before his parental rights could be terminated. Accordingly, we affirm the trial court’s order granting the prospective adoptive…