visits to telephone calls to the provision of photographs. Joseph R. Carrieri, “The Legal Handbook of the Foster Care System,” Criminal Law and Urban Problems, at 7 (PLI Litig. & Admin.Practice Course Handbook Series No. 163, 1992). “Open adoptions” engender sensitive and complex considerations of public policy. Amadio & Deutsch, supra, 22 J.Fam.L. at 66; Judy E. Nathan, Note, Visitation After Adoption: In the Best Interests of the Child, 59 N.Y.U.L.Rev. 633 (1984); Sandra Gardner, Beyond Records: Open Adoption, N.Y. Times, June 20, 1992 (N.J. Weekly), at 17. Courts have differed with respect to the clarity and strength of public policy on the issue of “open adoptions” under their respective statutory schemes. Compare In re Gregory B., 74 N.Y.2d 77, 544 N.Y.S.2d 535, 542 N.E.2d 1052 (<HOLDING>), reh’g denied sub nom. In re Willie John B.,
holding that postadoption visitation of child who was adopted by grandparents on basis of biological parents unconditional consent was required to promote childs best interests recognizing the relationships between a decedent and his or her parents and siblings recognizing emotional bond between foster parents and child although ultimately determining foster parents did not have rights of parents in dependency action under chapter 2644 rcw holding foster parents not liable for willful act of their foster child recognizing that postadoption visitation limited to when adoptive parents are grandparents siblings or foster parents