208 A.3d 762
Me.2019Background
- Jason Young and Toni King lived together beginning in 2004; King adopted a child from India in 2008 and thereafter refused Young’s request to adopt the child.
- Young lived with the child for several years, participated in daily caretaking (meals, hygiene, bedtime, daycare pickup), and signed adoption-related paperwork as a "father figure."
- After King moved in 2011, Young continued regular visitation (every other weekend and vacations) for about seven years, maintained the child’s bedroom and possessions, and the child referred to Young as "Dad/Daddy."
- In April 2018 King stopped visitation; Young then filed a complaint seeking adjudication as a de facto parent under the Maine Parentage Act (MPA), 19-A M.R.S. § 1891.
- The District Court dismissed for lack of standing, reasoning King’s refusal to allow adoption was dispositive evidence she did not accept Young as a parent; Young appealed.
- The Supreme Judicial Court vacated and remanded, holding the refusal to allow adoption is not dispositive and that a hearing was required because material facts were contested.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Young made the initial showing of standing under 19-A M.R.S. § 1891(2) | Young argued his affidavits showed residence, consistent caretaking, a bonded relationship fostered by King, acceptance of parental responsibilities, and that continued relationship served the child’s best interests | King argued her affidavits contradicted Young’s factual assertions and that her refusal to permit adoption showed she did not accept Young as a parent | Remanded: court erred to treat refusal to adopt as dispositive; where material facts are disputed, court should hold an evidentiary hearing on standing (or find undisputed prima facie evidence) |
| Whether a legal parent’s refusal to allow adoption is conclusive on § 1891(3)(C) (acknowledgment/acceptance) | Young: refusal to adopt is not dispositive when other conduct shows acceptance | King: refusal signals she did not regard Young as a parent | Held: Refusal to adopt is some evidence but not dispositive; court must assess all factual evidence regarding whether the legal parent understood, acknowledged, or behaved as though claimant was a parent |
| Proper procedure when affidavits contain disputed material facts on standing | Young: evidentiary hearing required to resolve contested facts before ruling on standing | King: district court may decide on papers; no hearing necessary if adoption refusal is dispositive | Held: If contested facts are necessary and material to standing, the court should (in its discretion) hold an expedited hearing to resolve them; court abused discretion by denying such a hearing here |
| Standard of proof at standing and merits stages | Young: standing is resolved by preponderance; merits require clear and convincing evidence | King: N/A (disputed facts affect ability to reach merits) | Held: Standing requires proof by preponderance; if standing established, de facto parentage merits require clear and convincing proof; consolidated hearing on both is permissible with sequential standards applied |
Key Cases Cited
- Kilborn v. Carey, 140 A.3d 461 (Me. 2016) (legal parent’s refusal to permit adoption is not dispositive where other conduct shows acceptance of claimant’s parental role)
- Davis v. McGuire, 186 A.3d 837 (Me. 2018) (describes MPA standing process and standards for preliminary standing showing)
- Lamkin v. Lamkin, 186 A.3d 1276 (Me. 2018) (appellate review standards for standing determinations; de novo legal review and clear‑error for facts)
- In re Estate of Wright, 637 A.2d 106 (Me. 1994) (abuse of discretion standard for certain trial‑court procedural decisions)
- Kinter v. Nichols, 722 A.2d 1274 (Me. 1999) (recognition that parental rights disputes are fact‑intensive and emotionally nuanced)