In re Estate of Hooper, 80 A.3d 815

Robert A. Hooper died intestate in 2003; initial probate filings listed his half-brother Vincent and step/half-siblings as heirs.
DNA testing showed Robert was not the biological son of Dean Hooper Sr., undermining the presumption that Dean was Robert’s father.
Putative Heirs (Dean Jr., Ronald, Linda) relied on the presumption of paternity and later on paternity by estoppel to claim a share of Robert’s estate; Gladys (Vincent’s widow) contested.
The Orphans’ Court initially applied the presumption of paternity, then on remand from the Superior Court was instructed to determine whether paternity by estoppel applied.
Gladys moved for summary judgment arguing paternity by estoppel is inapplicable; the Orphans’ Court granted summary judgment for Gladys without taking further evidence.
The Superior Court affirmed, holding paternity by estoppel does not extend to adult intestate succession claims by third parties and therefore Vincent’s estate is the sole beneficiary of Robert’s estate.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Orphans’ Court erred in granting summary judgment on Putative Heirs’ claim to be heirs of Robert’s estate	Bahl is factually distinguishable and should not bar applying paternity by estoppel here	Bahl controls; paternity by estoppel is limited to minor child support and should not be extended to adult intestate succession or third‑party claims	Court held Bahl dispositive; paternity by estoppel inapplicable as a matter of law; summary judgment for Gladys affirmed
Whether the Orphans’ Court abused discretion by failing to hold an evidentiary hearing on paternity by estoppel as previously directed	Appellants insist prior remand required an evidentiary hearing to determine estoppel	Once court correctly concluded estoppel was inapplicable as a matter of law, additional evidence would be unnecessary and wasteful	Court held no abuse: an evidentiary hearing was not required after legal determination that estoppel did not apply

Bahl v. Lambert Farms, 819 A.2d 534 (Pa. 2003) (declines to extend paternity‑by‑estoppel doctrine beyond minor support and not to third‑party succession claims)
Strauser v. Stahr, 726 A.2d 1052 (Pa. 1999) (framework: presumption of paternity → rebuttal → consider estoppel)
K.E.M. v. P.C.S., 38 A.3d 798 (Pa. 2012) (describes paternity‑by‑estoppel as deeming a person a parent where he held himself out as such; doctrine grounded in protecting minor children)
Michael Salove Co. v. Enrico Partners, L.P., 23 A.3d 1066 (Pa. Super. 2011) (summary judgment legal standard)