Van v. Zahorik

Brickley, J.

(dissenting). Like the majority, I agree that “[t]he present case presents tragic circumstances.” Ante at 337. I disagree, however, that “the current state of child custody law simply provides no means” for plaintiff to pursue parental rights, and I, therefore, respectfully dissent. Id. I would hold that, on this record, plaintiff has a legal stake in continuing the relationship he began with Zachary and Alicia at the time of their births, and, to that end, I agree with Justice Kelly’s dissenting opinion that this case be remanded to the trial court.

To say that this case does not involve delicate and complex questions of legal doctrine and policy would be disingenuous. Unfortunately, the majority’s approach creates an all-or-nothing resolution of such conflicts, in that it focuses on the adult’s marital status and “legal” relationship with the child, but ignores the equitable considerations presented by this case. The majority’s approach is particularly inadequate, as it devalues the importance of the child’s personal relationship with the putative father.

As a preliminary observation, the issue in this case is not, or at least should not be, sexual relationships or the marital status of the parties. Those factors should be considered, if at all, during a best interests hearing conducted by the circuit court pursuant to MCL 722.23; MSA 25.312(3). Rather, this Court’s focus should be on the innocent victims in this case, and many others like them: the children of dissolving nonmarital relationships. The issue is the best inter*339ests of these children and the role of the court in protecting them.

The deficiency in the majority opinion is the Court’s utilization of an adult-centered approach to resolve a dispute that primarily affects the lives and development of the children. Because children do not participate in the formation of their biological or legal child-parent relationships, they are wholly blameless for the shortcomings of their relatives — legal, biological, or otherwise. By placing an artificial restriction on the definition of “parent,” the majority absolves itself from addressing, as mandated by the Legislature, the organizing principle of the Child Custody Act: the best interests of the child.

The Child Custody Act, MCL 722.21 et seq.-, MSA 25.312(1) et seq., does not define the term “parent,” nor does it place a clear limitation on the right of biological strangers asserting parental rights from bringing custody actions. In the absence of a statutory definition of “parent” (which the Legislature could have expressly limited to adoptive or natural parentage), I cannot share the majority’s conclusion that plaintiff is somehow transformed into a “third party.” Black’s Law Dictionary refers to “parent” as comprehending “much more than [the] mere fact of who was responsible for [a] child’s conception and birth,” and is instead one who “share [s] mutual love and affection with a child and who supplies] child support and maintenance, instruction, discipline and guidance.”1

*340I agree with the majority that, in most cases, a narrow interpretation of the statutes conferring jurisdiction and standing to assert rights to custody and visitation is warranted.2 Significantly, however, the Legislature has not limited the status of legal parent to those with a biological, adoptive, or marital tie to a child, nor is there any indication that it intended that the Child Custody Act supplant or preempt the subject of visitation or the equitable powers of the circuit court to determine visitation under circumstances not expressly included within the statute. As Justice Kelly observes, § 6 provides that the act is “equitable in nature” and is to be “liberally construed.” Post at 343. Moreover, the best interests factors set forth in § 3 not only represent an equitable standard providing courts great latitude in protecting children, but § 5 clearly articulates a policy directing a court to consider the matters before it from the child’s perspective:

If a child custody dispute is between the parents, between agencies, or between third persons, the best interests of the child control. If the child custody dispute is between the parent or parents and an agency or a third person, the court shall presume that the best interests of the child are served by awarding custody to the parent or parents, unless the contrary is established by clear and convincing evidence. [MCL 722.25(1); MSA 25.312(5)(l).[3]

*341As I understand the majority opinion, as long as a petitioner is married to the biological mother, no matter how brief the duration of the marriage (a day, a week, a year?), the doctrine of equitable parenthood may be applied.4 The majority’s formulation that the equitable parenthood doctrine exists in the context of marriage contradicts its contention that the Legislature has “occupie[d] the field” in child custody matters, thereby precluding equitable considerations. Ante at 331. The majority also finds, without further explanation, that Michigan’s public policy favoring the institution of marriage supersedes the Legislature’s express directive that the “best interests” of the child control.5 Examined from the standpoint of the child, *342whom the Legislature deems most important, I cannot agree with the majority’s elevation of marriage as the sole relevant consideration. Such a formulation penalizes children for a decision by two unmarried adults to live together without the formality of marriage.

In sum, it bears emphasizing that granting plaintiff relief at this juncture does not mandate access to Zachary and Alicia. To the contrary, the decision to grant or deny visitation is the province of the circuit court, and only after deliberate consideration of what is in the best interests of the children. As used here, the Legislature enacted a standard involving competing goals and interests in which the “child’s interest” denotes a straightforward idea: a child’s stake in maintaining a relationship with an adult the child was told was a parent. The equitable parenthood doctrine best serves the child’s interests by focusing on two criteria: the “nonbiological parent’s” actual performance of parenting functions and the child’s view of that adult as a parent. Moreover, equitable parenthood permits a court to protect the interests of a biological parent’s autonomy by focusing on the actions and intent of that parent in creating a parental relationship.

I would remand this case to the circuit court for a determination of Zachary and Alicia’s best interests.

Cavanagh, J., concurred with Brickley, J.

Black’s Law Dictionary (6th ed), p 1114, citing Solberg v Metropolitan Life Ins Co, 50 Wis 2d 746, 753; 185 NW2d 319 (1971). See also American Heritage Dictionary (3d ed), p 1315 (“[o]ne who begets, gives birth to, or nurtures and raises a child,”).

The majority cites our decision in Bowie v Arder, 441 Mich 23; 490 NW2d 568 (1992), wherein we, inter alia, denied standing to a third party seeking custody. Given the factual context in Bowie, our holding does not control the present case: Bowie involved third parties (grandparents) who were never under the belief that they were the natural parents, nor, more significantly, were the children under the belief that they were their parents.

As Judge Markman observed in York v Morofsky, 225 Mich App 333, 338; 571 NW2d 524 (1997):

*341The child’s best interests are also of major concern in determining whether a party is an equitable parent .... Stability in acknowledged parent-child relationships is generally in the child’s best interests.

I question the majority’s statement that the equitable parent doctrine, as formulated in Atkinson v Atkinson, 160 Mich App 601; 408 NW2d 516 (1987), is “rooted in marriage.” Ante at 332. Although it is true that the Atkinson decision referred in passing to the fact that the child was conceived and bom during the parties’ marriage, the Court focused on the notion that

under certain circumstances, a person who is not the biological father of a child may be considered a parent when he desires such recognition and is willing to support the child as well as wants the reciprocal rights of custody or visitation afforded to a parent. [Atkinson at 610 (emphasis added).]

Defendant proffers a policy argument to the effect that to rule in plaintiff’s favor might reduce the amount of love a child needs because a custodial parent, concerned that a third-party relationship could ripen into a parental relationship, might not allow that contact. Such a contention is not only of dubious merit, but is irrelevant to the extent that it has no application to the instant facts: here, the defendant gave the children the plaintiff’s name on the birth certificate, led the plaintiff for years to believe that he was their parent, and filed a paternity action against the plaintiff (although later withdrawing it when the plaintiff’s blood tests were completed).