Tortious Interference with Parental Rights?

Is there a potential cause of action for interfering with a recognized constitutional right to parent your biological children? Although not yet recognized in Florida, The state of Virginia said Yes. The Virginia Supreme Court recognized this new cause of action where a women put her baby up for adoption through an agncy and allegedly conspired with the adoption agency and attorneys to do so without the knowledge or consent of the birth father. How this would come out in Florida is unknown, but this case could certainly be argued. In Florida we have a Putative Father Registry that any potentail father should register on. However, I see arguments against implementing such an onerous requirement on a potenital biological father as he would in essence have to file every time he had sexual relations with a woman to be protected. The Court in Virginia decided that damages for this tort included both tangible and intagible elements, including compensatory damages for expenses incurred in seeking recovery of the child, lost services, lost companionship, and mental anguish. Although no injunctive relief may be granted, punitive damages may be recovered when the interference is intentional.