GUZMAN v. GUZMAN
2021 OK 26
Okla.2021Background
- Child entered the household at birth (April 2015) and was formally adopted by Adrieanna Guzman on December 23, 2015. Carmen Guzman never adopted the child.
- Carmen and Adrieanna began their relationship in 2012 and married on February 18, 2017.
- The couple separated in September 2018. Carmen filed a petition for paternity on January 4, 2019 seeking adjudication of parental status, custody, and support; Adrieanna filed for dissolution and moved to dismiss the paternity petition.
- The trial court granted Adrieanna’s motion to dismiss for lack of standing; Carmen appealed.
- The Court of Civil Appeals reversed, relying on this Court’s decision in Schnedler v. Lee; the Supreme Court granted certiorari.
- The Oklahoma Supreme Court vacated the Court of Civil Appeals opinion and affirmed the trial court: a non-adopting step‑parent has no standing to seek paternity/custody/visitation under existing Oklahoma law, and Schnedler’s narrow holding does not extend to step‑parents in a marriage.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standing: Does a non-adopting spouse/step‑parent have standing to seek paternity/custody/visitation? | Carmen: She functioned as a parent and under Schnedler should be allowed to seek adjudication of parental status. | Adrieanna: Carmen never adopted the child; step‑parents have no statutory/common‑law right to custody/visitation and therefore lack standing. | Held: Carmen lacks standing. A spouse who never adopted the child is a step‑parent and has no statutory right to seek custody/visitation; dismissal affirmed. |
| Applicability of Schnedler: Does Schnedler extend to married step‑parents or to this factual posture? | Carmen / CCA: Schnedler’s parental‑recognition framework applies to non‑biological partners who acted as parents, so it should apply here. | Adrieanna: Schnedler is a limited equitable remedy for non‑married same‑sex co‑parents and does not create rights for step‑parents or alter statutory adoption rules. | Held: Schnedler is limited to its factual context (non‑biological same‑sex co‑parents who were not married) and does not confer standing on step‑parents in a marriage. |
Key Cases Cited
- Schnedler v. Lee, 445 P.3d 238 (Okla. 2019) (established an equitable framework for non‑biological same‑sex co‑parent standing; limited to its facts)
- Byers v. Byers, 618 P.2d 930 (Okla. 1980) (step‑parents do not automatically acquire parental status or support obligations)
- Leake v. Grissom, 614 P.2d 1107 (Okla. 1980) (parental visitation rights derive from parental custody rights)
- Eldredge v. Taylor, 339 P.3d 888 (Okla. 2014) (motion‑to‑dismiss/standing standard: accept petition allegations and inferences as true)
- In re Bomgardner, 711 P.2d 92 (Okla. 1985) (family‑law and child welfare matters are equitable in character)