S.F. Human Servs. Agency v. Heidi S. (In re Alexander P.)
S.F. Human Servs. Agency v. Heidi S. (In re Alexander P.)
Opinion of the Court
Alexander P. (minor), then three years old, became the subject of a dependency petition after his stepfather, Donald Q. (Donald) assaulted his mother, appellant Heidi S. (Mother), in the minor's presence. At the time of the filing of the dependency petition, the minor's paternity was the subject of competing motions filed in a family court action by two other men, appellants Michael P. (Michael) and Joel D. (Joel). Joel is the minor's biological father, while Michael is the man with whom Mother was living at the time of the minor's birth. Two weeks after the filing of the dependency petition, the family court ruled that both Michael and Joel qualify as presumed parents and designated both under Family Code
When the juvenile court inquired into the minor's paternity during the initial stages of this dependency proceeding, all three men sought to be declared the minor's presumed parent. Michael and Joel based their claims on the family court's order, while Donald provided evidence that he had, as a practical matter, served in the role of the minor's father for the 20 months prior to his assault on Mother. Considering itself bound by the family court's order, the juvenile court found both Michael and Joel to be presumed parents. The court also found that Donald satisfied the requirements for presumed parent status and designated him as well, pursuant to 7612, subdivision (c).
Michael and the minor have appealed the designation of Donald as a presumed parent, while several of the parties have challenged Michael's designation. In addition, Michael has challenged the juvenile court's subsequent denial to him of visitation with the minor.
We conclude that the juvenile court erred in finding Michael to be a presumed parent. Because Welfare and Institutions Code section 316.2 grants exclusive jurisdiction over paternity issues to the juvenile court upon the filing of a dependency petition, the family court order on which the juvenile court relied, issued subsequent to the filing, was void. The same reasoning applies to the designation of Joel as a presumed parent. We vacate the juvenile court's designation of Michael and Joel as presumed parents and remand to the juvenile court for an independent determination of their requests for presumed parent status. We find no error in the designation of Donald as a presumed parent, which was supported by substantial evidence. Finally, we vacate the juvenile court's order denying visitation to Michael and remand for reconsideration of his request in the event the court designates Michael as a presumed parent.
I. BACKGROUND
A. Presumed Parent Proceedings
The minor was conceived during an intermittent, three-year relationship between Mother and Michael, but neither believed Michael to be the child's biological father. When Mother informed Joel, whom she believed to be the father, of her pregnancy, Joel told her he was not ready for fatherhood and expressed concern about her decision not to abort the fetus. Mother thereafter ceased communication with Joel for well over a year.
Notwithstanding Michael's belief he was not the child's father, he remained in the relationship with Mother throughout her pregnancy, intending to raise the child as his own. Michael was present at the birth in February 2012, executed a voluntary *643declaration of paternity, and was identified as the minor's father on the birth certificate. During much of the first year of the minor's life, Michael lived with Mother, held himself out as the minor's father, and was characterized by Mother as " 'very attentive' " to the infant.
From before the minor's birth, the relationship between Mother and Michael was characterized by oppressive domestic violence. In January 2013, prior to the minor's first birthday, a criminal protective order issued to protect Mother from Michael. He was arrested for a separate act of domestic violence against her two months later and eventually suffered a misdemeanor conviction. A year later, in April 2014, another restraining order was granted in favor of Mother against Michael. She remained fearful of him long after.
At the time the first restraining order was entered, Michael filed a petition for custody of the minor. He and Mother eventually entered into a mediated stipulation providing for joint legal and physical custody and allowing Michael substantial visitation with the minor. But after entry of the April 2014 restraining order, Mother was granted sole legal and physical custody of the minor, and Michael was restricted to twice weekly supervised visits. Reports of the supervised visits found a loving and appropriate relationship between the minor and Michael, except Michael badgered the minor to refer to him as "Daddy." As will be discussed below, the supervised visits were later terminated by the family court.
In the meantime, in late 2013, Joel was given an opportunity to become involved in the minor's life and submitted to a DNA test, which confirmed he is the minor's biological father. Beginning in September 2013 and continuing to the present day, Mother has permitted Joel to have weekly visits with the minor, during which they have spent time together reading, talking, exploring, and playing in the park. Joel filed a paternity action in April 2014, which was eventually consolidated with Michael's custody petition.
In July 2013, Mother began living with Donald, whom she had known since high school. They married in August 2014. Within their household, it is acknowledged that Donald is not the minor's biological father, and Donald respects Joel's role in the minor's life. Nonetheless, Donald has assumed "the day-to-day physical and emotional responsibilities" of a father since he began living with Mother and the minor. Donald changed the minor's diapers and participated in his potty training, feeds and clothes him, puts him to sleep, and engages in typical parent-child play activities. Donald believes he treats the minor as his own child and is in turn regarded by the minor "as his psychological parent." By early 2015, the minor alternated between referring to Donald as "Don" and "Daddy," without coaching from Donald. Donald has introduced the minor to his extended family, who "have embraced [the minor] and accepted him into our family," and the minor has become "the center of attention at [Donald's] family functions." In a report prepared for the family court around June 2014, appointed counsel for the minor found the minor to be "most comfortable" in the care of Donald, rather than Michael or Joel.
*644On August 14, 2014, the family court conducted a hearing in the consolidated custody and paternity proceedings on two motions: a motion by Michael to compel Mother's compliance with the order granting him supervised visitation and Joel's motion for an order of paternity. Mother and Joel appeared in pro. per. for the hearing, but Michael did not attend because of a misunderstanding with respect to scheduling. Unaware of Michael's mistake, the family court set aside Michael's voluntary declaration of paternity, denied his claim of presumed parent status, vacated his visitation order, declared Joel to be a presumed parent, and awarded joint legal custody to Mother and Joel. If a judgment was entered on the basis of this order, it was not included in the appellate record.
Michael thereafter filed a request to set aside the orders entered in his absence and declare him to be the minor's legal father. Although Michael's request was filed in September 2014, the family court did not conduct an evidentiary hearing on the request until March 6, 2015. Following the March 6 hearing, in an order entered on March 17, 2015, the court vacated most of the orders entered after the August 2014 hearing, but it permitted the finding of presumed parent status for Joel and the suspension of Michael's visitation to remain in place pending issuance of its final decision on the issue of paternity.
Prior to any paternity ruling by the family court, on March 30, 2015, the San Francisco Human Services Agency (Agency) filed a dependency petition in connection with the minor. The petition alleged the minor, then three years old, was at risk of harm due to domestic violence in Mother's home. (Welf. & Inst. Code, § 300, subd. (b)(1).) According to the Agency's jurisdictional report, Donald, while intoxicated, had attacked Mother. With the minor watching from a hallway, Donald climbed on top of Mother and began striking her face, pulling her hair, and attempting to choke her. In tears, the minor rushed forward and attempted to pull Donald off. Donald was later arrested on domestic violence charges, and a restraining order was entered. The petition alleged this was only the most recent of five separate incidents of domestic violence by Donald against Mother.
Two weeks after the dependency petition was filed, on April 15, the family court issued a statement of decision, findings and order, and two judgments in the consolidated custody and paternity actions, finding both Joel and Michael to be presumed parents of the minor.
Soon thereafter, the juvenile court scheduled a hearing in the dependency proceedings "for status of Parentage." Prior to the hearing, Michael, Joel, and Donald all filed requests to be declared the minor's father. Michael also sought an order of visitation. In support of his request for presumed parent status, Donald submitted a declaration describing his relationship with the minor and stating that although he was required by a domestic violence restraining order to live apart from Mother and the minor, he intended to reunite with them when permitted to do so and to "remain[ ] [the minor's] father for the rest of his life."
On August 17, 2015, the juvenile court found Michael and Joel to be presumed parents on the basis of the family court's April 2015 order, deeming itself bound by that order. The court also found Donald to satisfy the requirements for presumed parent status and declared him to be the minor's third presumed parent, concluding it would be detrimental to the minor "to limit this child's parentage to mother, [Joel], and [Michael]." The court deferred a ruling on Michael's request for visitation, directing the parties to address it at a hearing scheduled for two days later.
At that hearing, the parties stipulated to an amended jurisdictional allegation. The juvenile court declared the minor to be a dependent and permitted him to remain with Mother, with the Agency directed to provide family maintenance services. The court also arranged to schedule separate trials on the issue of visitation for Michael and Donald and, in the meantime, directed both of them to mediation on the issue.
B. Michael's Visitation
II. DISCUSSION
Michael, Mother, Joel, and the minor have each appealed certain of the juvenile court's parentage rulings. Michael and the minor contend the court erred in finding Donald a presumed parent, while Mother, Joel, and the minor contend the court erred in finding Michael to be a presumed parent. In addition, Michael filed a separate notice of appeal from the court's order denying him visitation. We have consolidated all appeals for argument and decision.
A. Presumed Parentage Generally
"Presumed father status is governed by section 7611, which sets out several rebuttable presumptions under which a man may qualify for this status, generally by marrying or attempting to marry the child's mother or by publicly acknowledging paternity and receiving the child into his home. [Citations.] Biological fatherhood does not, in and of itself, qualify a man for presumed father status under section 7611. On the contrary, presumed father status is based on the familial relationship between the man and child, rather than any biological connection." (In re J.L. (2008)
If the child's biological mother and the potential presumed parent were not married or did not attempt to marry around the time of the child's birth, presumed parent status must be demonstrated through section 7611, subdivision (d), which requires, "The presumed parent receives the child into his or her home and openly holds out the child as his or her natural child." In general terms, the requirements of subdivision (d) are intended to describe a person who has established a "parent-child" or "familial" relationship with the child. (Jason P. v. Danielle S. (2014)
In J.L., we noted, "[o]ccasionally the complicated pattern of human relations gives rise to more than one legitimate claimant to presumed father status, and the juvenile court must resolve the competing claims. ... '[A]lthough more than one individual may fulfill the statutory criteria that give rise to a presumption of paternity, "there can be only one presumed father." ' " (J.L., supra , 159 Cal.App.4th at p. 1019,
B. Presumed Parent Status of Michael and Joel
Joel, Mother, and the minor have all appealed the designation of Michael as a presumed parent, arguing the juvenile court erred in concluding it was bound by the family court's April 2015 order because that court, by the time it ruled, no longer had subject matter jurisdiction over the issue of paternity. We agree.
Section 7630 permits certain persons with a specified relationship to a child to bring an action in family court to determine the existence of presumed parent status under section 7611. (§ 7630, subds. (a)-(c).) Once a dependency petition has been filed, however, Welfare and Institutions Code section 316.2 vests the court hearing the dependency petition with exclusive responsibility for determining the identity of presumed parents, stating, "After a petition has been filed to declare a child a dependent of the court, and until the time that the petition is dismissed, ... the juvenile court which has jurisdiction of the dependency action shall have exclusive jurisdiction to hear an action filed under Section 7630 or 7631 of the Family Code."
*648The juvenile court's exclusive jurisdiction over parentage issues, once a Welfare and Institutions Code section 300 dependency petition has been filed, was recognized by our Supreme Court in In re Jesusa V. (2004)
The necessary effect of a grant of exclusive subject matter jurisdiction in one judicial body is to divest all other bodies of such jurisdiction. (El Rancho Unified School Dist. v. National Education Assn. (1983)
Michael argues the juvenile court was bound by the family court's judgment finding him to be a presumed father under the doctrines of collateral estoppel and res judicata. Both of those doctrines are premised on the assumption that the judgment for which preclusive effect is sought was rendered by a court of competent jurisdiction. Judgments that are void for lack of " 'jurisdiction in the fundamental sense, i.e., of the subject matter and the parties' " have no preclusive effect. (People v. American Contractors Indemnity Co. (2004)
Joel and the Agency argue we need not remand for an independent consideration of Michael's request for presumed parent status because there is no substantial evidence to support such a finding, but we are unwilling to address that issue before the juvenile court has had an opportunity to do so. For the same reason, we also decline to address the significance, if any, of Michael's voluntary declaration of paternity. The various issues bearing on Michael's presumed parent status must be resolved in the first instance by the juvenile court.
Our conclusion unavoidably calls into question the presumed parent status of Joel. No party has challenged the juvenile court's finding that Joel is a presumed father of the minor, but the reasoning that requires us to vacate the finding as to Michael applies with equal force to Joel. If the juvenile court erred in designating Michael on the basis of the April 2015 order, it also erred in designating Joel. For that reason, we asked for supplemental briefing addressing the proper disposition of the juvenile court's designation of Joel as a presumed father if the April 2015 order was found to be void. Michael argues the order should be vacated because "no other evidence exists in the appellate record to support" the designation. The remaining parties argue the two men are distinct because Joel, unlike Michael, was declared to be a presumed father in orders rendered by the family court at a time when it had jurisdiction over the issue, on August 15, 2014 and March 17, 2015. Accordingly, they reason, the juvenile court's error was *650harmless because it would have been bound by these earlier orders.
While we acknowledge this difference between Michael and Joel, the parties have not suggested a viable theory under which the family court's orders became binding on the juvenile court, thereby excusing that court from making an independent determination of Joel's presumed father status. It is true "one trial court judge may not reconsider and overrule a ruling of another judge" (Curtin v. Koskey (1991)
Accordingly, we also vacate the finding of presumed father status for Joel and remand to the juvenile court for reconsideration of that issue.
C. Designation of Donald As a Presumed Parent
Michael and the minor argue the juvenile court's order designating Donald a presumed parent was not supported by substantial evidence. A person seeking presumed parent status has the burden of demonstrating compliance with the statutory requirements by a preponderance of the evidence. ( *651R.M., supra ,
1. Donald's Qualification for Presumed Parent Status
We find no merit in the argument that Donald failed to demonstrate an entitlement to presumed father status.
Michael contends Donald failed to provide evidence he satisfies the statutory requirement to "openly hold[ ] out the child as his or her natural child" (§ 7611, subd. (d)) because he has not claimed biological parentage of the minor and admitted in a declaration that he, Mother, and the minor "all acknowledge that [the minor] has a different biological father." Still, compliance with this portion of the subdivision does not require proof that the presumed parent claims the child as his or her biological child. As noted, a presumed parent need not be a biological parent (In re Jesusa V. , supra ,
*652What is required, rather, is that the presumed parent treat the child as though the child was his or her own by developing a parental relationship and taking on " ' " 'parental responsibilities-emotional, financial, and otherwise.' " ' " (In re Jovanni B. (2013)
Michael relies in part on In re Spencer W. (1996)
In contrast to the claimant in Spencer W., there is no evidence that Donald is acting out of convenience, without the underlying commitment to the minor expected of a parent. He is married to the minor's mother, treats the minor as his child, and claims an intent to continue to do so. While it is true, as Michael argues, that Donald never attempted to establish paternity in the family law proceedings filed by Michael and Joel, the juvenile court was not required to draw any particular inference from his failure. Since none of the parties were represented by counsel in that proceeding, it is unclear whether Donald understood his rights and options. Once he was provided counsel in the context of this proceeding, Donald promptly asserted his claim to paternity. Nor do we find it determinative that Donald, Mother, and the minor acknowledge Joel's biological paternity. That has not prevented the minor from referring to Donald as "Daddy." One can treat a person as a one's parent, and be treated as a child in return, while acknowledging a different biological reality.
Michael also contends Donald failed to satisfy the portion of section 7611, *653subdivision (d) requiring a presumed parent to "receive [ ] the child into his or her home" because Donald stated in his declaration he "moved in" with Mother and the minor in July 2013, from which Michael infers the family now lives in a home owned or rented by Mother. But there is no requirement that a presumed parent prove he or she rents or owns a residence in order to qualify as a presumed parent. One's "home" is the place where one resides. The evidence is clear that Donald has received the minor into his home, albeit a home that may be owned or rented by Mother.
Finally, Michael contends Donald should be disqualified from presumed parent status because it was Donald's commission of domestic violence toward Mother in the minor's presence that resulted in the minor's detention. There is some support in decisional law for the argument. In T.R., supra ,
While we do not mean to minimize the significance of Donald's abuse of Mother, we do not find it disqualified him as a matter of law from acquiring presumed parent status. The violence, while committed in the minor's presence, was not directed at the minor. As such, we do not find Donald's conduct so "antithetical to a parent's role" and such a "blatant violation of *654parental responsibilities" that it "counterbalanced the factors favoring" presumed parent status. (T.R., supra , 132 Cal.App.4th at p. 1211,
Michael urges us to follow In re Kieshia E. (1993)
2. "Detriment" Under Section 7612
Michael maintains the juvenile court erred in finding the minor would suffer a detriment if Donald was not designated a presumed father, the finding necessary for the designation of more than one presumed parent under section 7612, subdivision (c).
As noted above, prior to 2013, the juvenile court was precluded from designating more than one presumed parent. If two persons qualified, the court was required to choose between them, based on "considerations of policy and logic." (§ 7612, subd. (b).) Now, more than one presumed parent can be designated if to do otherwise "would be detrimental to the child." (Id. subd. (c).)
Section 7612, subdivision (c) was recently explored at length in Donovan L. , supra ,
In reversing the juvenile court's order under section 7612, subdivision (c), the court discussed the legislative history of the amendment at length. "Detriment" was selected as a standard for permitting more than one presumed parent after the Governor *655vetoed a bill that would have made the decision dependent on the " 'best interest of the child.' " (Donovan L. , supra , 244 Cal.App.4th at p. 1089, fn. 12,
Given this interpretation of the detriment requirement, there was substantial evidence to support the juvenile court's conclusion it would be detrimental not to designate Donald as a presumed parent. As discussed above, the minor has an established, parental relationship with Donald, likely stronger than his relationships with either Joel or Michael. Preserving such a relationship is precisely the purpose of the amendment to section 7612 to permit multiple presumed parents.
Michael argues Donald's domestic violence supports a finding that it would not be detrimental to deny Donald presumed parent status. While the juvenile court might permissibly have reached that conclusion, we find no abuse of discretion in the court's decision to favor preservation of the minor's strongest parental relationship, notwithstanding his domestic violence. Michael also challenges the strength of the minor's bond with Donald, pointing out they had lived together for only 20 months. Twenty months, however, is a significant portion of the minor's young life. In any event, the juvenile court's contrary conclusion is supported by substantial evidence, for the reasons discussed in connection with Donald's designation as a presumed parent.
Finally, Michael contends that finding Donald to be a presumed parent "circumvents the purpose of stepparent adoption statutes." Being declared a presumed parent, he argues, permits Donald to "achieve a potentially custodial status" with the minor *656without going through the process established by section 9000 et seq. for the adoption of a child by his or her stepparent. In effect, Michael argues, if a stepparent is to be designated a presumed parent, that person should be required to adopt the child; conversely, if a stepparent has not seen fit to adopt, presumed parent status should be denied. In considering this argument, it must be remembered that adoption and presumed parent status serve different purposes. Adoption is available generally to stepparents, while designation of a presumed parent normally occurs in the context of a dependency proceeding. Given the potentially critical importance of a presumed parent in the life of a child who is subject to a dependency proceeding, we see no reason to place roadblocks to the achievement of that status by otherwise qualified persons, including stepparents, by imposing requirements not found in the Family Code provisions bearing on presumed parent status. In the absence of an indication by the Legislature that adoption is intended to be the exclusive means by which a stepparent is to be granted custodial status, we find no basis for denying presumed parent status to otherwise qualified stepparents.
D. Denial of Visitation to Michael
III. DISPOSITION
The juvenile court's orders finding Michael and Joel to be presumed parents and denying visitation to Michael are vacated. The order finding Donald to be a presumed parent is affirmed. Following remand, the juvenile court is directed to hear and render a decision on Michael's and Joel's requests for presumed parent status. If either or both are found qualified, the court must consider the potential detriment to the minor of a denial of presumed parent status for the qualifying person(s). If Michael is designated a presumed parent, the juvenile court shall also reconsider Michael's request for visitation.
We concur:
Humes, P.J.
Dondero, J.
All statutory references are to the Family Code unless otherwise specified.
Michael contends the juvenile court could not consider this report because "counsel's statements are not evidence." While this is true when an attorney is acting in the role of an advocate, the report in question was rendered by counsel acting in the role of a witness. (See Rules Prof. Conduct, rule 5-200(E).) In any event, the juvenile court is entitled to consider certain types of hearsay evidence (Welf. & Inst. Code, § 355 ), and Michael fails to demonstrate he objected to the consideration of this report below (In re E.B. (2010)
Only the family court's statement of decision is included in our appellate record. We have obtained a copy of the findings and order and the two judgments from the superior court and take judicial notice of them. The four rulings together will be referred to as the family court's "April 2015 order."
See footnote *, ante .
Since our decision in J.L., section 7611 has been amended to refer to a presumed "parent" rather than "father," recognizing that the second parent of a child may be female as well as male. (Stats. 2013, ch. 510, § 3; e.g., Elisa B. v. Superior Court (2005)
Section 7612, subdivision (c) provides, as pertinent: "In an appropriate action, a court may find that more than two persons with a claim to parentage under this division are parents if the court finds that recognizing only two parents would be detrimental to the child. In determining detriment to the child, the court shall consider all relevant factors, including, but not limited to, the harm of removing the child from a stable placement with a parent who has fulfilled the child's physical needs and the child's psychological needs for care and affection, and who has assumed that role for a substantial period of time."
Michael argues the parties have forfeited this issue by failing to raise it below. While the parties opposed the juvenile court's adoption of the family court ruling regarding Michael, they failed to raise the specific issue of lack of jurisdiction in the family court. Because the family court's jurisdiction is a significant issue of law going to the legal foundation for the juvenile court's order, we exercise our discretion to consider it. (See, e.g., In re Nickolas T. (2013)
Section 7631 was repealed effective January 1, 2011 (Stats. 2010, ch. 588, § 2), notwithstanding the continued reference in Welfare and Institutions Code section 316.2.
Welfare and Institutions Code section 316.2, subdivision (a) requires the fatherhood inquiry to be made at the detention hearing "or as soon thereafter as practicable." By statute, the detention hearing must occur "before the expiration of the next judicial day" after filing of the petition. (Welf. & Inst. Code, § 315.)
The juvenile court made no finding with respect to detriment if Michael were not found to be a presumed parent (§ 7612, subd. (c) ), presumably viewing itself to be bound by the detriment finding of the family court. Should the juvenile court find on remand that Michael qualifies as a presumed parent, it should proceed to consider the issue of detriment under section 7612, subdivision (c), assuming there is more than one person qualified for presumed parent status.
Michael also argues it would be inequitable, unfair, or bad public policy to disregard the family court's judgment. In light of the clear statutory directive that issues of paternity must be litigated in the context of a dependency proceeding, once the proceeding is filed, we have no equitable discretion in the matter.
Because of the importance of the family court proceedings, we obtained various documents from the superior court, including orders entered in the family court proceedings on August 15, 2014 and March 17, 2015, and a copy of the docket sheet. Notwithstanding the family court's statement in its April 2015 order, there is no entry for a judgment in the docket sheet prior to April 2015. The Agency has filed a request to take judicial notice of the March 17, 2015 order. We grant that request and also take judicial notice of the August 15, 2014 order and the docket sheet for the family court proceedings.
In doing so, we do not mean to suggest any opinion about the merits of Joel's request for presumed parent status. We merely recognize that a person must be properly found by the juvenile court to satisfy the requirements of presumed parent status in order to be so designated.
Donald raises a series of procedural objections to the arguments of Michael and the minor, contending they lack standing to raise the issues or have forfeited their arguments by not raising them below. We have considered Donald's contentions and satisfied ourselves that Michael, at least, has standing and has not forfeited a challenge to Donald's designation as a presumed father. Because we find no merit in the arguments raised by Michael and the minor with respect to Donald, it is unnecessary to discuss the issues of standing and forfeiture in detail.
In reaching this conclusion, we do not to mean to suggest that a presumed parent's words are necessarily irrelevant. If a potential presumed parent disclaims biological parentage under circumstances suggesting an intent to avoid the responsibilities of parenthood, that disclaimer would certainly be relevant to the "openly holds out" requirement. There is no evidence in the record that Donald's acknowledgment of Joel's biological parentage was intended in this manner.
The record is unclear about the financial arrangements of the couple. Donald owned or rented a home in 2011, but it is not known whether Mother and the minor moved into that home in July 2013, or whether, as the language of the declaration suggests, Donald moved into a residence they were already occupying. Further, and contrary to Donald's claim that he "provid[ed] food, shelter and clothes for the child for almost two years," there is no information in the declaration as to Donald's contribution to the family's finances. While evidence that Donald was helping to support the minor financially would have been useful in demonstrating his commitment, the absence of such evidence does not disqualify him.
Michael also argues, on the basis of references in legislative history documents, that the amendment permitting more than one presumed parent was not intended to apply to stepparents. We decline to infer such an important exception from comments in the legislative history that are not reflected in the text of the legislation. In any event, those references merely indicated the authors' belief that stepparents would rarely qualify for presumed parent status. They do not indicate an intent to bar otherwise qualifying stepparents.
See footnote *, ante .
Case-law data current through December 31, 2025. Source: CourtListener bulk data.