Titchenal v. Dexter

Morse, J.,

dissenting. I respectfully dissent. The Court rejects plaintiff’s effort to establish visitation with the minor child on the ground that there is no legal right by which the court might fashion *387an equitable remedy, and the Court is unwilling to create a new legal right of “equitable parentage.” Although other courts have embraced the concept, see, e.g., In re Custody of H.S.H.-K., 533 N.W.2d 419 (Wis.), cert. denied, Knott v. Holtzman, 516 U.S. 975, 116 S. Ct. 475 (1995) (court may grant visitation to former lesbian partner if petitioner proves parent-like relationship with minor child), I agree with the Court that the social implications of the equitable-parent doctrine are sufficiently complex that any major policy decision in this area properly rests with the Legislature. That is not, however, the only avenue of relief available to plaintiff.

As explained more fully below, the doctrine of “equitable adoption” provides an alternative, well-established remedy that is well suited to the factual circumstances of this case. Based on the law as it was reasonably understood at the time, plaintiff was compelled to forego the opportunity, together with her partner, to adopt the minor child as any other married couple could have done. That law subsequently changed, and so, unfortunately, did plaintiff’s domestic circumstances. It is too late apparently for the parties to cooperate, but not for the law to provide a just remedy, by permitting plaintiff to establish an intent to adopt and thus preserve the critically important parent-child relationship.

The Court dismisses this approach out of hand. Apart from a rather unrestrained accusation of unprincipled special pleading on behalf of plaintiff, the actual reasons offered by the Court unravel upon detached analysis. This is not a particularly difficult case. Although the context is novel, the legal principle is settled and the facts are compelling.

As we observed in Whitchurch v. Perry, 137 Vt. 464, 470-71, 408 A.2d 627, 631 (1979) (emphasis added):

Courts generally apply the doctrine of equitable adoption in cases of intestate succession to permit participation in the estate by a foster child who was never legally, i.e., statutorily, adopted by the decedent. . . Custody is transferred and the child lives with the foster parent as would a natural child, but, for one reason or another ... an adoption never occurs. Upon the foster parent’s death, a court, applying the maxim that “equity regards that as done which ought to be done,” declares that the child is entitled to share in the estate as if he were a legally adopted child.

Although courts have traditionally characterized the concept as an equitable remedy for an unperformed “contract” to adopt, in reality *388the agreement “to adopt is found when a close relationship, similar to parent-child, exists between a child and the deceased.” Atkinson v. Atkinson, 408 N.W.2d 516, 520 (Mich. Ct. App. 1987); see also First Nat’l Bank v. Phillips, 344 S.E.2d 201, 203 (W Va. 1985) (rejecting contract notion as “unnecessary fiction” and relying instead on evidence of love and affection between parent and child and outward representations of parent-child relationship). An agreement to adopt may be inferred from the “acts, conduct and admissions of the parties and other relevant facts and circumstances,” Cavanaugh v. Davis, 235 S.W.2d 972, 975 (Tex. 1951), which might include such evidentiary facts as an assumption by the child of the deceased’s surname, identification of the deceased as the child’s parent on school and other formal records, and, most significantly, evidence of a relationship of love and affection between the deceased and the child. The concept of equitable adoption has been recognized both in Vermont, Whitchurch, 137 Vt. at 470-71, 408 A.2d at 631, and broadly across the country. See Annotation, Modern Status of Law as to Equitable Adoption or Adoption by Estoppel, 97 A.L.R.3d 347 (1980) (collecting cases).

While equitable adoption most commonly involves a child’s effort to share in the intestate estate of a foster parent who had intended to adopt, it has been applied in a variety of other contexts. It has been invoked, for example, to entitle a child to maintain an action for the wrongful death of a foster parent where the evidence disclosed an unconsummated intent to adopt. See Holt v. Burlington Northern R.R., 685 S.W.2d 851, 857 (Mo. Ct. App. 1984); Bower v. Landa, 371 P.2d 657, 661 (Nev. 1962). It has also been extended to allow a parent to obtain the death benefits of a child under a workers’ compensation statute where the evidence disclosed an unfulfilled intent to adopt the deceased child. Jones v. Loving, 363 P.2d 512, 515 (Okla. 1961). And in a recent Michigan case, the doctrine was invoked to support the parental rights of a nonbiological father to the daughter born while he was married to the mother. Atkinson, 408 N.W.2d at 520.

We need not go as far as the Michigan court, which adopted the broader doctrine of equitable parentage, id. at 519, to recognize that the principle of equitable adoption has valid applications outside the context of inheritance law. Here I propose an application much closer to the original equitable-adoption concept. The purpose of the doctrine, as noted, is to allow a court to find, in retrospect, an intent to adopt by a person who had never formally done so, for the purpose of achieving a just result. Flaintiff in this matter contends that she would have adopted the minor child when she was born in 1991, but *389that the adoption statute then appeared to allow only one nonmarried person to adopt, and defendant was designated as the adoptive parent. The rules of adoption were liberalized in 1993, when the Court recognized the right of a nonmarried parental partner to adopt, see In re B.L.V.B., 160 Vt. 368, 369-73, 628 A.2d 1271, 1272-74 (1993), and substantially revised in 1996, when the Legislature enacted a new adoption statute formally recognizing the right of nonmarried cohabitants to freely adopt. See 15A V.S.A. § l-102(b) (if family consists of parent and parent’s partner, and adoption is in child’s best interest, partner of parent may adopt child without terminating parent’s rights); see also 15A V.S.A. § l-102(a) (“[A]ny person may adopt or be adopted by another person for the purpose of creating the relationship of parent and child between them.”).

Given these subsequent rule changes, plaintiff, in my view, should be accorded the opportunity to demonstrate on remand that, except for the perceived legal impediment in light of her personal circumstances at that time, she would have adopted the minor child as did defendant. Plaintiff should be allowed to prove, in other words, an intent to establish an adoptive relationship with the child that was never formally consummated because of the then current state of the law. All that this amounts to, in effect, is application of the principle of equitable adoption in a novel factual context — a retrospective inquiry by the court into whether plaintiff intended, but because of the then-current adoption statute failed, to effectuate an adoption of the minor child, to the end of achieving a fair result.

In such a proceeding, plaintiff would be allowed to adduce evidence identical to that generally considered to be material in the equitable-adoption context — reciprocal love and affection between parent and child, holding-out as the parent, “parental” designation on official forms, and the like. Indeed, without purporting to prejudge the issue, I would note in this regard that plaintiff alleges she was the minor child’s primary caretaker: she dressed and fed the minor every morning before driving her to daycare, spent extensive time with the minor playing, talking and reading, and exercised primary responsibility for the minor during the evening. Plaintiff also allegedly shares a surname with the minor (“Dexter-Titchenal”) and is listed as the minor’s parent on her daycare enrollment form, probate records, and baptismal papers. Defendant’s last will and testament further states that plaintiff has “shared in the parenting of [the minor] since the day [she] came into [their] lives.” Should plaintiff establish these allegations at trial and persuade the court of her intent to adopt, she would *390be accorded the legal status of an adoptive parent, and the family court could then resolve the visitation issue as though it were a regular dissolution proceeding, determining what is in the best interests of the child.

In adopting this approach, the court would not be “creating” any new legal rights; adoptive parents have all of the rights and responsibilities of a natural parent, including the right, upon termination of the parents’ relationship, to seek visitation. 15A Y.S.A. §§ 1-104, 1-112. We merely apply a settled equitable remedy — equitable adoption — to recognize retrospectively the adoptive relationship between plaintiff and the minor in order to achieve an equitable result.

As for the proper court in which to adjudicate plaintiff’s claim, the Legislature has recently made it clear that family court is the appropriate venue. As expressly provided in 15A V.S.A. § 1-112:

The family court shall have jurisdiction to hear and dispose of issues pertaining to parental rights and responsibilities, parent-child contact and child support. . . under the following circumstances:
(1) If two unmarried persons, who have adopted a minor child, terminate their domestic relationship;

(Emphasis added.) Furthermore, the family court has “all of the equitable . . . powers of the superior court as to civil matters within its jurisdiction.” 4 V.S.A. § 453(a). Thus, if the family court finds that plaintiff intended to adopt the minor child, it would adjudicate the matter as any other dissolution between “two unmarried persons, who have adopted a minor child,” 15A V.S.A. § 1-112(1), resolving visitation rights and related issues in the best interests of the child.

A decision along these lines would present none of the drawbacks of a broader holding recognizing the rights of “equitable parents.” It would apply only to this case, and any other in which a party allegedly failed to adopt because it was not a reasonable legal option. It is safe to assume that the courts will not be flooded with similar claims. Indeed, the number of potential claimants is finite by definition, since the holding would apply only to those who, like plaintiff, allegedly failed to adopt prior to the 1996 statutory changes in the adoption law. This approach also shields the family courts from the most common and problematic situation in which a cohabitant lives with the natural parent and child for some period of time, separates, and then seeks parental rights. Since the parties could have married and the *391cohabitant could have adopted, our holding would plainly not extend to them. In sum, a holding along the lines outlined above holds the promise of fairness, yet avoids the real risks, identified by the Court, of a broader-based holding recognizing the rights of equitable parents.

The Court, nevertheless, rejects this approach on three grounds. First, it claims the family court lacks jurisdiction to adjudicate such a matter. As explained above, however, the family court is expressly empowered to “hear and dispose of issues pertaining to parental rights and responsibilities [of]. . . two unmarried persons, who have adopted a minor child,” 15A V.S.A. § 1-112, and is further vested with full “equitable . . . powers” to determine whether one of the parties is entitled to adoptive-parent status. 4 V.S.A. § 453(a).

Second, the Court rather colorfully chides the dissent for “stretching the doctrine . . . beyond recognition in an effort to provide relief to this particular plaintiff” while providing no “principled” justification or limitation. 166 Vt. at 384,693 A.2d at 689. These are the same old stale and discredited charges that “law” has brought against “equity” since the days of Henry II. The principle in this case is indeed suited to this plaintiff, but that makes it no more “unprincipled” than any other equitable doctrine, unless the Court also considers equitable estoppel, equitable servitudes, constructive trusts, specific performance, and every other equitable remedy to be unprincipled. Furthermore, there is a plain and principled basis for extending the equitable-adoption doctrine to this plaintiff (and anyone similarly situated) and no further, that the Court simply ignores. Plaintiff was effectively barred from adopting the minor by the law in effect when she and defendant were together. This unique fact justifies an extension of equitable relief to this plaintiff, and establishes a principled basis to exclude others who might wish to take advantage of the doctrine.

Finally, the Court advances the remarkable proposition that plaintiff somehow could, and should, have attempted to adopt the minor child prior to the couple’s separation in 1994. The Court observes that one probate court in 1991 had allowed an adoption in similar circumstances, and that in 1993 we issued our decision in B.L.V.B. broadening the right of nonmarried cohabitants to adopt. It is one thing to presume that parties are aware of, and bound by, general enactments of the Legislature that amend the law; it is quite another, however, to impute to a nonattorney specific knowledge of one probate decision and a later, confirming appellate court decision. The *392rule that everyone is presumed to know the law, and the corollary that ignorance of the law is no excuse, is a rule of necessity designed to ensure that mere ignorance does not immunize one who commits a crime from its penal consequences. See Brent v. State, 43 Ala. 297, 302 (1869) (“[T]hat everybody is presumed to know the law . . . is a rule of presumption, adopted from necessity, and to avoid an evil that would otherwise constantly perplex the courts, in the administration of the criminal law; that is, the plea of ignorance.”). As one court has observed, however, “[t]he necessity does not go farther in civil matters so as to punish, punitively, on the strength of the legal presumption, which more often than otherwise is against the truth.” Topolewski v. Plankinton Packing Co., 143 Wis. 52, 73 (1910). It would be contrary to common sense and fairness to conclude that plaintiff, or anyone similarly situated, should have known that she had the legal right to adopt prior to the effective date of 15A V.S.A. § 1-102.

It is especially unfair in this case to assert, as the Court does, that plaintiff somehow “slumbered” and was less than vigilant. Plaintiff and defendant wanted a child to raise together as their own. They were not seeking to become a “test case” for the rights of gay and lesbian parents, nor should they have been expected to do so. They obeyed the law as it was then reasonably understood, and they had no cause to challenge it. They could not anticipate that the law would change, any more than they could anticipate that their relationship would change. But change they did, and by then it was too late to obtain the cooperation from defendant that would have avoided this dispute. It is wrong to suggest that plaintiff somehow brought this problem upon herself.

For all of the foregoing reasons, I would remand the matter to the family court for further proceedings consistent with the views expressed herein. Justice Johnson joins in the dissent.