Richards v. Reiter
796 N.W.2d 509
Minn.2011Background
- Richards petitioned for joint legal custody and parenting time for D.T.R.; Marthe and Reiter named as parties; genetic testing in 2008 showed Richards as biological father; district court adjudicated Reiter as D.T.R.'s father; Marthe appealed the paternity ruling but Richards did not; Court of Appeals dismissed Marthe's appeal for lack of standing; this Court reverses and remands for further proceedings.
- Trial record included stipulation that Richards is biological father; competing paternity presumptions under Minn. Stat. ch. 257; district court weighed presumptions under Minn. Stat. § 257.55 and § 257.62; paternity determination did not resolve custody or support.
- District court found Reiter’s paternity presumptions outweighed Richards based on weightier considerations of policy and logic; paternity order affected child support and custody/controls.
- Marthe argues she has standing as aggrieved party under case law and the Minnesota Parentage Act; Reiter argues she has no standing because her rights are not directly affected by paternity.
- The issue presented: whether Marthe has standing to appeal the district court’s paternity adjudication.
- The Court holds Marthe has standing as an aggrieved party because paternity affects her child support obligation and care, custody, and control rights; case is reversed and remanded for further proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Marthe has standing to appeal the paternity adjudication. | Marthe has aggrieved-party standing due to child support and custody rights. | Marthe’s rights are not affected by paternity adjudication; standing lacking. | Marthe has standing; reversed and remanded. |
Key Cases Cited
- State v. Sax, 231 Minn. 1 (1950) (mother aggrieved to appeal paternity-related award of support)
- State v. E.A.H., 246 Minn. 299 (1956) (mother has standing due to direct pecuniary interest in child support and paternity outcome)
- Singer v. Allied Factors, Inc., 216 Minn. 443 (1944) (aggrieved-party concept; injury to a legally protected right)
- Twin Cities Metro. Pub. Transit Area v. Hotter, 311 Minn. 423 (1977) (form of aggrieved-party requirement aligns with Rule 103.03)
- Enright v. Lehmann, 735 N.W.2d 326 (Minn. 2007) (standing as a jurisdictional issue; de novo review)
- Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (three elements of standing)