In People in Interest of S.A.H., the South Dakota Supreme Court held that open adoptions, or post-adoption visitation by the natural parents, while not prohibited under South Dakota law when in the best interests of the child, should only be mandated when the trial court finds that it is in the best interests of the child by clear and convincing evidence. The court also instructed trial courts to weigh the needs of the child, the effect on integration with the new family, and the potential effect on the pool of other prospective adoptive parents. This decision, while securing judicial enforcement of consensual open adoptions, presents an inordinately difficult standard for mandating open adoptions.