C.L. v. L.L. in Re A.L., 125 A.3d 350

C.L., who knew he was not A.L.’s biological father, lived with A.L. (born 2005) during his marriage to A.L.’s mother, L.L.; he later sought de facto parent status.
Divorce judgment (Oct 2012) provided shared parental rights by agreement but did not adjudicate de facto parenthood; child support for A.L. continued pending genetic testing.
DHHS placed A.L. in protective custody in 2013; genetic testing confirmed a different man as A.L.’s biological father, and the court later established his parentage.
A.L. remained placed in C.L.’s home for a time, but evidence at trial showed poor housing, lack of routine, hygiene and school problems while she lived with C.L.; placement with paternal grandmother later stabilized and improved A.L.’s wellbeing.
C.L. moved for de facto parent status in both the child protection and family (divorce) matters; after a consolidated two-day trial the court denied de facto status in both proceedings.
C.L. appealed; the Supreme Judicial Court dismissed the appeal from the child protection order as interlocutory and affirmed the family-court judgment denying de facto parenthood.

Issue	Plaintiff's Argument (C.L.)	Defendant's Argument (State/Parents)	Held
Whether the child protection-side order denying de facto status is appealable	C.L.: court misapplied de facto-parent doctrine; merits review warranted	State: child protection interlocutory orders are not appealable under 22 M.R.S. § 4006	Dismissed as interlocutory; no constitutional challenge raised
Whether C.L. is a de facto parent under common law	C.L.: he undertook a parental role over years and exceptional circumstances justify intrusion on legal parents’ rights	Parents/State: C.L. failed to show a permanent, responsible parental role; exceptional-circumstances not met	Denied — C.L. failed to prove the required parental-role element
Whether the trial court made sufficient findings of fact	C.L.: court lacked sufficient findings about his pre-protection parental involvement	State/Parents: court made extensive, supported findings about C.L.’s parenting capacity and effects on A.L.	Affirmed — findings were extensive and supported by competent evidence
Whether exceptional circumstances existed to override legal parents’ rights	C.L.: argued exceptional circumstances warranted de facto status	Parents/State: no exceptional circumstances shown; adding legal parent would harm relationships	Court did not reach merits after deciding first prong failed; affirmance of denial (court had also found exceptional circumstances lacking)

Pitts v. Moore, 90 A.3d 1169 (Me. 2014) (sets two-part common-law test for de facto parenthood)
In re L.R., 97 A.3d 602 (Me. 2014) (child-protection orders under Title 22 are interlocutory and generally not appealable)